Data processing systems for central consent repository and related methods

ABSTRACT

A data processing central consent repository system may be configured to, for example: (1) identify a form used to collect one or more pieces of personal data, (2) determine a data asset of a plurality of data assets of the organization where input data of the form is transmitted, (3) add the data asset to the third-party data repository with an electronic link to the form, (4) in response to a user submitting the form, create a unique subject identifier to submit to the third-party data repository and, along with the form data provided by the user in the form, to the data asset, (5) submit the unique subject identifier and the form data provided by the user to the third-party data repository and the data asset, and (6) digitally store the unique subject identifier and the form data in the third-party data repository and the data asset.

CROSS REFERENCE TO RELATED APPLICATIONS

This application is a continuation-in-part of U.S. patent applicationSer. No. 17/013,758, filed Sep. 7, 2020, which is a continuation of U.S.patent application Ser. No. 16/820,346, filed Mar. 16, 2020, now U.S.Pat. No. 10,769,303, Sep. 8, 2020, which is a continuation of U.S.patent application Ser. No. 16/563,749, filed Sep. 6, 2019, now U.S.Pat. No. 10,592,692, issued Mar. 17, 2020, which is acontinuation-in-part of U.S. patent application Ser. No. 16/409,673,filed May 10, 2019, now U.S. Pat. No. 10,452,864, issued Oct. 22, 2019,which is a continuation of U.S. patent application Ser. No. 16/159,635,filed Oct. 13, 2018, now U.S. Pat. No. 10,289,867, issued May 14, 2019,which claims priority from U.S. Provisional Patent Application Ser. No.62/572,096, filed Oct. 13, 2017 and U.S. Provisional Patent ApplicationSer. No. 62/728,435, filed Sep. 7, 2018, and is also acontinuation-in-part of U.S. patent application Ser. No. 15/996,208,filed Jun. 1, 2018, now U.S. Pat. No. 10,181,051, issued Jan. 15, 2019,which claims priority from U.S. Provisional Patent Application Ser. No.62/537,839, filed Jul. 27, 2017, and is also a continuation-in-part ofU.S. patent application Ser. No. 15/853,674, filed Dec. 22, 2017, nowU.S. Pat. No. 10,019,597, issued Jul. 10, 2018, which claims priorityfrom U.S. Provisional Patent Application Ser. No. 62/541,613, filed Aug.4, 2017, and is also a continuation-in-part of U.S. patent applicationSer. No. 15/619,455, filed Jun. 10, 2017, now U.S. Pat. No. 9,851,966,issued Dec. 26, 2017, which is a continuation-in-part of U.S. patentapplication Ser. No. 15/254,901, filed Sep. 1, 2016, now U.S. Pat. No.9,729,583, issued Aug. 8, 2017, which claims priority from: (1) U.S.Provisional Patent Application Ser. No. 62/360,123, filed Jul. 8, 2016;(2) U.S. Provisional Patent Application Ser. No. 62/353,802, filed Jun.23, 2016; and (3) U.S. Provisional Patent Application Ser. No.62/348,695, filed Jun. 10, 2016. The disclosures of all of the abovepatent applications are hereby incorporated herein by reference in theirentirety.

BACKGROUND

Over the past years, privacy and security policies, and relatedoperations have become increasingly important. Breaches in security,leading to the unauthorized access of personal data (which may includesensitive personal data) have become more frequent among companies andother organizations of all sizes. Such personal data may include, but isnot limited to, personally identifiable information (PII), which may beinformation that directly (or indirectly) identifies an individual orentity. Examples of PII include names, addresses, dates of birth, socialsecurity numbers, and biometric identifiers such as a person'sfingerprints or picture. Other personal data may include, for example,customers' Internet browsing habits, purchase history, or even theirpreferences (e.g., likes and dislikes, as provided or obtained throughsocial media).

Many organizations that obtain, use, and transfer personal data,including sensitive personal data, have begun to address these privacyand security issues. To manage personal data, many companies haveattempted to implement operational policies and processes that complywith legal and industry requirements. However, there is an increasingneed for improved systems and methods to manage personal data in amanner that complies with such policies.

Similarly, as individuals have become more aware of the risks associatedwith the theft or misuse of their personal data, they have soughtadditional tools to help them manage which entities process theirpersonal data. There is currently a need for improved tools that wouldallow individuals to minimize the number of entities that process theirpersonal data—especially entities that the individual doesn't activelydo business with.

SUMMARY

A method, according to various embodiments, may include: analyzing, bycomputing hardware, a webform used to collect personal data to identifya data asset configured to receive the personal data collected by thewebform; transmitting, by the computing hardware, an instruction to aconsent repository to generate an electronic link at the consentrepository associating the webform and the data asset; detecting, by thecomputing hardware, a submission of the webform and form data associatedwith the webform; generating, by the computing hardware and based on theform data, a unique subject identifier for a user associated with thesubmission of the webform; transmitting, by the computing hardware, aninstruction to the consent repository causing the consent repository tostore and associate the unique subject identifier and the form data;transmitting, by the computing hardware, an instruction to the dataasset causing the data asset to store and associate the unique subjectidentifier and the form data; detecting, by the computing hardware, arequest for access to personal data associated with the user and requestdata associated with the request; determining, by the computing hardwareand based on the request data, the unique subject identifier using theconsent repository; determining, by the computing hardware and based onthe unique subject identifier and the form data, the data asset usingthe consent repository; retrieving, by the computing hardware and basedon the unique subject identifier, the personal data from the data asset;and generating, by the computing hardware, a graphical user interfacefor display on a user device, the graphical user interface presentingthe personal data.

In particular embodiments, the method may include: transmitting aninstruction to the consent repository causing the consent repository togenerate a data map comprising the unique subject identifier, anindication of the data asset, and an electronic link associating theunique subject identifier and the indication of the data asset. Inparticular embodiments, determining the data asset using the consentrepository comprises determining the data asset based on the uniquesubject identifier using the data map. In particular embodiments,transmitting the instruction to the consent repository causing theconsent repository to generate the data map comprises using anapplication programming interface to transmit the instruction to theconsent repository causing the consent repository to generate the datamap. In particular embodiments, analyzing the webform to identify thedata asset comprises: analyzing the webform to identify a processingactivity associated with the webform; and determining the data assetbased on the processing activity using a data map associated with theprocessing activity. In particular embodiments, generating the uniquesubject identifier comprises: determining that the consent repositorydoes not store data associated with the user; and in response todetermining that the consent repository does not store the dataassociated with the user, generating the unique subject identifier. Inparticular embodiments, generating the unique subject identifiercomprises: detecting browser data in a browser application executed on auser device, the browser data comprising user data; and generating theunique subject identifier based on the user data.

A system, according to various embodiments, may include: anon-transitory computer-readable medium storing instructions; andprocessing hardware communicatively coupled to the non-transitorycomputer-readable medium, wherein the processing hardware is configuredto execute the instructions and thereby perform operations comprising:scanning a webform used to collect personal data to determine adestination data asset to which the personal data collected by thewebform is transmitted; transmitting an instruction to a consentrepository to generate an electronic link at the consent repositoryassociating the webform and the destination data asset; detecting asubmission of the webform and form data associated with the webform;determining a unique subject identifier for a user associated with thesubmission of the webform based on the form data; transmitting aninstruction to the consent repository causing the consent repository tostore and associate the unique subject identifier and the form data;transmitting an instruction to the destination data asset causing thedestination data asset to store and associate the unique subjectidentifier and the form data; detecting a request for access to personaldata associated with the user and request data associated with therequest; determining the unique subject identifier based on the requestdata using the consent repository; determining the destination dataasset based on the unique subject identifier and the form data using theconsent repository; retrieving a subset of the personal data from thedestination data asset based on the unique subject identifier; andgenerating a graphical user interface for display on a user device, thegraphical user interface presenting the personal data.

In particular embodiments, determining the unique subject identifiercomprises: determining that the consent repository stores dataassociated with the user; and in response to determining that theconsent repository stores the data associated with the user, retrievingthe unique subject identifier from the consent repository. In particularembodiments, detecting the request for access to the personal datacomprises detecting browser data in a browser application executed on auser device, the browser data comprising the request data and a datasubject parameter identifying the user. In particular embodiments,detecting the submission of the webform and the form data comprisesdetecting browser data in a browser application executed on a userdevice, the browser data comprising the form data and indication of thesubmission of the webform. In particular embodiments, the operations mayfurther include: transmitting an instruction to the consent repositorycausing the consent repository to modify a data map associated with theunique subject identifier to include an indication of the destinationdata asset and an electronic link associating the unique subjectidentifier and the indication of the destination data asset. Inparticular embodiments, the operations may further include: determininga second data asset based on the unique subject identifier using thedata map; and retrieving a second subset of the personal data from thesecond data asset based on the unique subject identifier. In particularembodiments, generating the graphical user interface comprises:generating the graphical user interface for a browser applicationexecuted on a user device by configuring a display element configured todisplay the personal data on the graphical user interface; andtransmitting an instruction to the browser application causing thebrowser application to retrieve the personal data and present thegraphical user interface on the user device.

A non-transitory computer-readable medium, according to variousembodiments, may store computer-executable instructions that, whenexecuted by processing hardware, configure the processing hardware toperform operations comprising: analyzing a webform used to collectpersonal data to identify a data asset configured to receive thepersonal data collected by the webform; transmitting an instruction to aconsent repository to generate an electronic link at the consentrepository associating the webform and the data asset; detecting asubmission of the webform and form data associated with the webform, theform data comprising consent data; determining a unique subjectidentifier for a user associated with the submission of the webformbased on the form data; transmitting an instruction to the consentrepository causing the consent repository to store and associate theunique subject identifier and the form data; transmitting an instructionto the data asset causing the data asset to store and associate theunique subject identifier and the form data; receiving a request foraccess to personal data associated with the user and request dataassociated with the request; determining the unique subject identifierusing the consent repository based on the request data; determining thedata asset using the consent repository based on the unique subjectidentifier and the form data; retrieving the personal data from the dataasset based on the unique subject identifier; and generating a graphicaluser interface for display on a user device, the graphical userinterface presenting the personal data.

In particular embodiments, the operations further comprise: transmittingan instruction to the consent repository causing the consent repositoryto generate a data inventory comprising the unique subject identifier,an indication of the data asset, the consent data, and an electroniclink associating the unique subject identifier, the consent data, andthe indication of the data asset. In particular embodiments, determiningthe data asset using the consent repository comprises determining thedata asset based on the unique subject identifier using the datainventory. In particular embodiments, retrieving the personal data fromthe data asset comprises determining the consent data asset based on theunique subject identifier using the data inventory; and retrieving thepersonal data from the data asset is further based on the consent data.In particular embodiments, generating the graphical user interfacecomprises: generating the graphical user interface for a browserapplication executed on a user device based on the consent data byconfiguring a first display element configured to display the personaldata on the graphical user interface and excluding a second displayelement configured to display a denial of access to the personal datafrom the graphical user interface; and transmitting an instruction tothe browser application causing the browser application to retrieve thepersonal data and present the graphical user interface on the userdevice. In particular embodiments, detecting the submission of thewebform and form data comprises detecting browser data in a browserapplication executed on a user device, the browser data comprising theconsent data.

A computer-implemented data processing method for identifying one ormore pieces of personal data that are not associated with the one ormore privacy campaigns of a particular entity, in particularembodiments, comprises: (1) accessing, by one or more processors, viaone or more computer networks, to one or more data assets of theparticular entity; (2) scanning, by one or more processors, the one ormore data assets to generate a catalog of one or more privacy campaignsand one or more pieces of personal information associated with one ormore individuals; (3) storing, by one or more processors, the generatedcatalog in computer memory; (4) scanning, by one or more processors, oneor more data assets based at least in part on the generated catalog toidentify a first portion of the one or more pieces of personal data thatare one or more pieces of personal data that are not associated with theone or more privacy campaigns; (5) generating, by one or moreprocessors, an indication that the first portion of one or more piecesof personal data that are not associated with the one or more privacycampaigns of the particular entity is to be removed from the one or moredata assets; (6) presenting, by one or more processors, the indicationto one or more individuals associated with the particular entity; and(7) removing, by one or more processors, the first portion of the one ormore pieces of personal data that are not associated with the one ormore privacy campaigns of the particular entity from the one or moredata assets.

A computer-implemented data processing method for removing one or morepieces of personal data that are not associated with the one or moreprivacy campaigns of a particular entity, in particular embodiments,comprises: (1) accessing, by one or more processors, via one or morecomputer networks, one or more data models that map an associationbetween (i) one or more pieces of personal data associated with one ormore individuals stored within one or more data assets of the particularentity and (ii) one or more privacy campaigns of the particular entity;(2) analyzing, by one or more processors, the one or more data models toidentify a first portion of the one or more pieces of personal data thatare one or more pieces of personal data that are not associated with theone or more privacy campaigns; and (3) automatically removing the firstportion of the one or more pieces of personal data that are notassociated with the one or more privacy campaigns of the particularentity from the one or more data assets.

Various embodiments are also described in the following listing ofconcepts:

1. A computer-implemented data processing method for identifying one ormore pieces of personal data that are not associated with one or moreprivacy campaigns of a particular entity, the method comprising:

accessing, by one or more processors, via one or more computer networks,one or more data assets of the particular entity;

scanning, by one or more processors, the one or more data assets togenerate a catalog of one or more privacy campaigns and one or morepieces of personal information associated with one or more individuals;

storing, by one or more processors, the generated catalog in computermemory;

scanning, by one or more processors, one or more data assets based atleast in part on the generated catalog to identify a first portion ofthe one or more pieces of personal data that are one or more pieces ofpersonal data that are not associated with the one or more privacycampaigns;

generating, by one or more processors, an indication that the firstportion of one or more pieces of personal data that are not associatedwith the one or more privacy campaigns of the particular entity is to beremoved from the one or more data assets;

presenting, by one or more processors, the indication to one or moreindividuals associated with the particular entity; and

removing, by one or more processors, the first portion of the one ormore pieces of personal data that are not associated with the one ormore privacy campaigns of the particular entity from the one or moredata assets.

2. The computer-implemented data processing method of Concept 1, whereinthe first portion of the one or more pieces of personal data that arenot associated with the one or more privacy campaigns of the particularentity are automatically removed from the one or more data assets.

3. The computer-implemented data processing method of Concept 1, furthercomprising:

determining that one or more privacy campaigns have been terminatedwithin the one or more data assets of the particular entity;

scanning the one or more data assets based at least in part on thegenerated catalog to identify the one or more pieces of personal datathat are associated with the terminated one or more privacy campaigns;and

generating an indication that the one or more pieces of personal datathat are associated with the terminated one or more privacy campaignsare included in the first portion of the one or more pieces of personaldata.

4. The computer-implemented data processing method of Concept 3, furthercomprising:

determining that one or more privacy campaigns of the particular entityhave not been utilized in a period of time; and

terminating the one or more privacy campaigns of the particular entitythat have not been utilized in the period of time.

5. The computer-implemented data processing method of Concept 4, whereinthe period of time is ninety or more days.

6. The computer-implemented data processing method of Concept 1, whereinpresenting the indication to the one or more individuals associated withthe particular entity further comprises:

receiving, by one or more processors, a selection, by the one or moreindividuals associated with the particular entity, of a first set of theone or more pieces of personal data of the first portion of the one ormore pieces of personal data to retain based on one or more bases toretain the first set of the one or more pieces of personal data;

prompting, by one or more processors, the one or more individuals toprovide one or more bases to retain the first set of the one or morepieces of personal data of the first portion of the one or more piecesof personal data that are not associated with the one or more privacycampaigns;

receiving, by one or more processors, the provided one or more bases toretain the first set of the one or more pieces of personal data of thefirst portion of the one or more pieces of personal data from the one ormore individuals associated with the particular entity;

retaining, by one or more processors, the first set of the one or morepieces of personal data of the first portion of the one or more piecesof personal data from the one or more individuals associated with theparticular entity; and

removing a second set of the one or more pieces of personal data of thefirst portion of the one or more pieces of personal data that are notassociated with the one or more privacy campaigns from the one or moredata assets, wherein the second set of the one or more pieces ofpersonal data is different from the first set of the one or more piecesof personal data and the first portion of the one or more pieces ofpersonal data comprise the first set of the one or more pieces ofpersonal data and the second set of the one or more pieces of personaldata.

7. The computer-implemented data processing method of Concept 6, furthercomprising:

in response to receiving the provided one or more bases to retain thefirst set of the one or more pieces of personal data from the one ormore individuals associated with the particular entity, submitting theprovided one or more bases to retain the first set of the one or morepieces of personal data to one or more second individuals associatedwith the particular entity for authorization.

8. The computer-implemented data processing method of Concept 6, whereinthe second set of the one or more pieces of personal data does notinclude one or more pieces of personal data.

9. A computer-implemented data processing method for removing one ormore pieces of personal data that are not associated with one or moreprivacy campaigns of a particular entity, the method comprising:

accessing, by one or more processors, via one or more computer networks,one or more data models that map an association between (i) one or morepieces of personal data associated with one or more individuals storedwithin one or more data assets of the particular entity and (ii) one ormore privacy campaigns of the particular entity;

analyzing, by one or more processors, the one or more data models toidentify a first portion of the one or more pieces of personal data thatare one or more pieces of personal data that are not associated with theone or more privacy campaigns; and

automatically removing the first portion of the one or more pieces ofpersonal data that are not associated with the one or more privacycampaigns of the particular entity from the one or more data assets.

10. The computer-implemented data processing method of Concept 9,further comprising:

receiving, by one or more processors, an indication of a new privacycampaign initiated by the particular entity;

in response to receiving the indication of the new privacy campaigninitiated by the particular entity, modifying the one or more datamodels to map an association between (i) one or more pieces of personaldata associated with one or more individuals obtained in connection withthe new privacy campaign and (ii) the new privacy campaign initiated bythe particular entity.

11. The computer-implemented data processing method of Concept 9,further comprising:

generating an indication that the first portion of the one or morepieces of personal data that are not associated with the one or moreprivacy campaigns of the particular entity is to be removed from the oneor more data assets of the particular entity; and

presenting the indication to one or more individuals associated with theparticular entity.

12. The computer-implemented data processing method of Concept 9,further comprising:

determining that one or more privacy campaigns have been terminatedwithin the one or more data assets of the particular entity;

analyzing, by one or more processors, the one or more data models toidentify one or more pieces of personal data that are one or more piecesof personal data that are associated with the terminated one or moreprivacy campaigns; and

generating an indication that the one or more pieces of personal datathat are associated with the terminated one or more privacy campaignsare included in the first portion of the one or more pieces of personaldata.

13. The computer-implemented data processing method of Concept 12,further comprising:

determining that one or more privacy campaigns of the particular entityhave not been utilized in a period of time; and

terminating the one or more privacy campaigns of the particular entityhave not been utilized in the period of time.

14. The computer-implemented data processing method of Concept 13,wherein the period of time is ninety or more days.

15. A computer-implemented data processing method for generating aprivacy data report of a particular entity, the method comprising:

accessing, by one or more processors, via one or more computer networks,one or more data models that map an association between (i) one or morepieces of personal information of one or more individuals stored withinone or more data assets of the particular entity and (ii) one or moreprivacy campaigns of the particular entity;

accessing, by one or more processors,

-   -   a data collection policy of the particular entity that is based        at least in part on one or more collection parameters defining        how one or more pieces of personal data of one or more        individuals is collected by the particular entity and one or        more storage parameters associated with storing the one or more        pieces of personal data of the one or more individuals, and    -   one or more data retention metrics of the particular entity that        are based at least in part on the collection and storage by the        particular entity of the one or more pieces of personal data of        one or more individuals;

analyzing, by or more processors, the one or more data models toidentify one or more pieces of personal data that are not associatedwith the one or more privacy campaigns;

generating, by one or more processors, a privacy data report based atleast in part on (i) analyzing the one or more data models to identifyone or more pieces of personal data that are not associated with the oneor more privacy campaigns, (ii) the data collection policy of theparticular entity, and (iii) the one or more data retention metrics ofthe particular entity; and

providing, by one or more processors, the privacy data report to one ormore individuals associated with the particular entity.

16. The computer-implemented data processing method of Concept 15,wherein the privacy data report comprises a comparison of the datacollection policy and the one or more data retention metrics of theparticular entity to one or more industry standard data collectionpolicies and one or more industry standard data retention metrics.

17. The computer-implemented data processing method of Concept 15,wherein generating the privacy data report further comprises:

calculating a data risk score for the particular entity based at leastin part on (i) analyzing the one or more data models to identify one ormore pieces of personal data that are not associated with the one ormore privacy campaigns, (ii) the data collection policy of theparticular entity, and (iii) the one or more data retention metrics ofthe particular entity.

18. The computer-implemented data processing method of Concept 17,further comprising:

comparing the data risk score for the particular entity to a thresholddata risk score;

determining that the data risk score for the particular entity is lessthan the threshold data risk score;

in response to determining that the data risk score for the particularentity is less than the threshold risk score, generating a notificationto indicate that the data risk score for the particular entity is lessthan the threshold risk score; and

providing the notification to the one or more individuals associatedwith the particular entity.

19. The computer-implemented data processing method of Concept 17,further comprising:

comparing the data risk score for the particular entity to a thresholddata risk score;

determining that the data risk score for the particular entity isgreater than or equal to the threshold data risk score;

in response to determining that the data risk score for the particularentity is greater than the threshold risk score, generating anotification to indicate that the data risk score for the particularentity is greater than the threshold risk score; and

providing the notification to the one or more individuals associatedwith the particular entity.

20. The computer-implemented data processing method of Concept 15,wherein the one or more data retention metrics comprise at least onedata retention metric selected from a group consisting of:

a storage location of the one or more pieces of personal data;

a period of time the one or more pieces of personal data are stored bythe particular entity;

a number of the one or more privacy campaigns accessing the one or morepieces of personal data; and

an amount of the one or more pieces of personal data being collected bythe particular entity.

A computer-implemented data processing method for generating a privacydata report of a particular entity, in particular embodiments,comprises: (1) accessing, by one or more processors, via one or morecomputer networks, one or more data models that map an associationbetween (i) one or more pieces of personal information of one or moreindividuals stored within one or more data assets of the particularentity and (ii) one or more privacy campaigns of the particular entity;(2) accessing, by one or more processors, (i) a data collection policyof the particular entity that based at least in part on one or morecollection parameters defining how one or more pieces of personal dataof one or more individuals is collected by the particular entity and oneor more storage parameters associated with storing the one or morepieces of personal data of the one or more individuals, and (ii) one ormore data retention metrics of the particular entity that are based atleast in part on the collection and storage by the particular entity ofthe one or more pieces of personal data of one or more individuals; (3)analyzing, by or more processors, the one or more data models toidentify one or more pieces of personal data that are not associatedwith the one or more privacy campaigns; (4) generating, by one or moreprocessors, a privacy data report based at least in part on (i)analyzing the one or more data models to identify one or more pieces ofpersonal data that are not associated with the one or more privacycampaigns, (ii) the data collection policy of the particular entity, and(iii) the one or more data retention metrics of the particular entity;and (5) providing, by one or more processors, the privacy data report toone or more individuals associated with the particular entity.

A data management computer system for confirming a deletion of personaldata associated with a data subject from one or more computer systemsassociated with an entity, in particular embodiments, comprises: (1) oneor more computer processors; and (2) computer memory operatively coupledto the one or more processors, wherein the one or more computerprocessors are adapted for: (a) receiving an indication that the entityhas completed an erasure of one or more pieces of personal dataassociated with the data subject under a right of erasure; (b) inresponse to receiving the indication that the entity (e.g., one or morecomputer systems associated with the entity) has completed the erasure,initiating a test interaction between a test data subject and theentity, the test interaction requiring a response from the entity to thetest data subject; (c) in response to initiating the test interaction,determining whether one or more system associated with the entity havetransmitted the response to the test data subject; and (d) in responseto determining that the one or more systems associated with the entityhave transmitted the response, (i) determining that the entity has notcompleted the erasure of the one or more pieces of personal dataassociated with the test data subject, and (ii) automatically taking oneor more actions with regard to the personal data associated with thetest data subject.

A data management computer system for confirming a deletion of personaldata associated with a data subject from one or more computer systemsassociated with an entity, in particular embodiments, comprises: (1) oneor more computer processors; and (2) computer memory operatively coupledto the one or more processors, wherein the one or more computerprocessors are adapted for: (a) receiving an indication that the entityhas completed an erasure of one or more pieces of personal dataassociated with a test data subject under a right of erasure; (b) inresponse to receiving the indication that the entity has completed theerasure, initiating a test interaction between a test data subject andthe entity, the test interaction requiring a response from the entity tothe test data subject; (c) in response to initiating the testinteraction, determining whether one or more system associated with theentity have initiated a test interaction response to the data subjectbased at least in part on the test interaction; and (d) in response todetermining that the one or more systems associated with the entity haveinitiated the test interaction response, (i) determining that the entityhas not completed the erasure of the one or more pieces of personal dataassociated with the data subject, and (ii) automatically taking one ormore actions with regard to the personal data associated with the datasubject.

A computer-implemented data processing method, in particularembodiments, comprises: (1) providing a communication to the entity,wherein the communication, (a) comprises a unique identifier associatedwith the data subject, (b) is performed without using a personalcommunication data platform, and (c) prompts the entity to provide aresponse by contacting the data subject via a personal communicationdata platform; (2) in response to providing the communication to theentity, determining whether the data subject has received a response viathe personal communication data platform; (3) in response to determiningthat the data subject has received the response via the personalcommunication data platform, determining that the entity has notcomplied with the data subject's request for deletion of their personaldata by the entity; (4) in response to determining that the entity hasnot complied with the data subject's request for deletion, generating anindication that the entity has not complied with the data subject'srequest for deletion of their personal data by the entity; and (5)digitally storing the indication that the entity has not complied withthe data subject's request for deletion of their personal data incomputer memory.

Various embodiments are also described in the following listing ofconcepts:

1. A data management computer system for confirming a deletion ofpersonal data associated with a data subject from one or more computersystems associated with an entity, the system comprising:

-   -   one or more computer processors; and    -   computer memory operatively coupled to the one or more        processors, wherein the one or more computer processors are        adapted for:        -   receiving an indication that the one or more computer            systems have completed an erasure of one or more pieces of            personal data associated with the data subject;        -   in response to receiving the indication that the one or more            computer systems have completed the erasure, initiating a            test interaction between the data subject and the entity,            the test interaction requiring a response from the entity to            the data subject;        -   in response to initiating the test interaction, determining            whether one or more computer systems associated with the            entity have initiated a test interaction response to the            data subject based at least in part on the test interaction;            and        -   in response to determining that the one or more computer            systems associated with the entity have initiated the test            interaction response:            -   determining whether the one or more computer systems                have completed the erasure of the one or more pieces of                personal data associated with the data subject; and            -   automatically taking one or more actions with regard to                the personal data associated with the data subject.

2. The data management computer system of Concept 1, wherein the one ormore actions comprise:

identifying the one or more pieces of personal data associated with thedata subject that remain stored in the one or more computer systems ofthe entity;

flagging the one or more pieces of personal data associated with thedata subject that remain stored in the one or more computer systems ofthe entity; and

providing the flagged one or more pieces of personal data associatedwith the data subject that remain stored in the one or more computersystems of the entity to an individual associated with the entity.

3. The data management computer system of Concept 1, wherein:

initiating the test interaction between the data subject and the entitycomprises substantially automatically completing a contact-request formhosted by the entity on behalf of the data subject.

4. The data management computer system of Concept 3, wherein:

substantially automatically completing the contact-request formcomprises providing one or more pieces of identifying data associatedwith the data subject, the one or more pieces of identifying datacomprising data other than contact data.

5. The data management computer system of Concept 4, wherein determiningwhether the one or more system associated with the entity have generatedthe test interaction response, further comprises:

determining whether the one or more computer systems of the entity haveattempted to contact the data subject in response to submission of thecontact-request form.

6. The data management computer system of Concept 1, wherein the methodfurther comprises initiating a test interaction between the data subjectand the entity in response to determining that a certain period of timehas elapsed from a time that the data subject provided the request todelete the data subject's personal data.

7. The data management computer system of Concept 6, wherein the testinteraction is automatically initiated by the computer system.

8. The data management computer system of Concept 1, wherein the one ormore actions comprise:

generating a report indicating that one or more pieces of personal dataassociated with the data subject remain stored in the one or morecomputer systems of the entity; and

providing the report to an individual associated with the entity.

9. A data management computer system for confirming deletion of personaldata within one or more computer systems associated with an entity, thesystem comprising:

-   -   one or more computer processors; and    -   computer memory operatively coupled to the one or more        processors, wherein the one or more computer processors are        adapted for:        -   receiving an indication that the one or more computer            systems have completed an erasure of one or more pieces of            personal data associated with a test data subject;        -   in response to receiving the indication that the one or more            computer systems have completed the erasure, initiating a            test interaction between a test data subject and the entity,            the test interaction requiring a response from the entity to            the test data subject;        -   in response to initiating the test interaction, determining            whether the one or more computer systems associated with the            entity have transmitted the response to the test data            subject;        -   in response to determining that the one or more computer            systems associated with the entity have transmitted the            response:            -   determining whether the one or more computer systems                have completed the erasure of the one or more pieces of                personal data associated with the test data subject; and            -   automatically taking one or more actions with regard to                the personal data associated with the test data subject.

10. The data management computer system of Concept 9, wherein the one ormore actions comprise:

identifying the one or more pieces of personal data associated with thetest data subject that remain stored in the one or more computer systemsof the entity;

flagging the one or more pieces of personal data associated with thetest data subject that remain stored in the one or more computer systemsof the entity; and

providing the flagged one or more pieces of personal data associatedwith the test data subject that remain stored in the one or morecomputer systems of the entity to an individual associated with theentity.

11. The data management computer system of Concept 9, wherein:

initiating the test interaction between the test data subject and theentity comprises substantially automatically completing acontact-request form hosted by the entity on behalf of the test datasubject.

12. The data management computer system of Concept 11, wherein:

substantially automatically completing the contact-request formcomprises providing one or more pieces of identifying data associatedwith the test data subject, the one or more pieces of identifying datacomprising data other than contact data.

13. The data management computer system of Concept 12, furthercomprising:

determining whether the one or more computer systems associated with theentity have generated the response and transmitted the response to thetest data subject comprises determining whether the one or more computersystems have attempted to contact the test data subject in response tosubmission of the contact-request form.

14. The data management computer system of Concept 13, wherein themethod further comprises initiating a test interaction between the datasubject and the entity in response to determining that a certain periodof time has elapsed from a time that the data subject provided therequest to delete the data subject's personal data.

15. The data management computer system of Concept 14, wherein the testinteraction is automatically initiated by the computer system.

16. The data management computer system of Concept 9, wherein the one ormore actions comprise:

generating a report indicating that one or more pieces of personal dataassociated with the test data subject that remain stored in the one ormore computer systems of the entity; and

providing the report to an individual associated with the entity.

17. A computer-implemented data processing method for monitoringcompliance by a particular entity with a data subject's request todelete the data subject's personal data from one or more computersystems associated with a particular entity, the method comprising:

providing a communication to the entity, wherein the communication:

-   -   (a) comprises a unique identifier associated with the data        subject;    -   (b) is performed without using a personal communication data        platform, and    -   (c) prompts the entity to provide a response by contacting the        data subject via a personal communication data platform;

in response to providing the communication to the entity, determiningwhether the data subject has received a response via the personalcommunication data platform;

in response to determining that the data subject has received theresponse via the personal communication data platform, determiningwhether the one or more computer systems have executed the datasubject's request for deletion of the data subject's personal data;

in response to determining that the one or more computer systems havenot complied with the data subject's request for deletion, generating anindication that the one or more computer systems have not complied withthe data subject's request for deletion of the data subject's personaldata; and

digitally storing in computer memory the indication that the one or morecomputer systems have not complied with the data subject's request fordeletion of the data subject's personal data.

18. The computer-implemented data processing method of Concept 17,further comprising:

identifying one or more pieces of personal data associated with the datasubject that are stored in the one or more computer systems of theentity;

flagging the one or more pieces of personal data associated with thedata subject that are stored in the one or more computer systems of theentity; and

providing the flagged one or more pieces of personal data associatedwith the data subject that are stored in the one or more computersystems of the entity to an individual associated with the entity.

19. The computer-implemented data processing method of Concept 17,further comprising:

generating a report based at least in part on the indication that theentity has not complied with the data subject's request for deletion oftheir personal data in computer memory; and

providing the generated report to an individual associated with theentity.

20. The computer-implemented data processing method of Concept 19,wherein the individual associated with the entity is a privacy officerof the entity.

A computer-implemented method for updating risk remediation data for anentity, in particular embodiments, comprises: (1) accessing riskremediation data for an entity that identifies one or more actions toremediate a risk in response to identifying one or more data assets ofthe entity potentially affected by one or more risk triggers; (2)receiving an indication of an update to the one or more data assets; (3)identifying one or more updated risk triggers for an entity based atleast in part on the update to the one or more data assets; (4)determining, by using one or more data models associated with the riskremediation data, one or more updated actions to remediate the one ormore updated risk triggers; (5) analyzing the one or more updated risktriggers to determine a relevance of the risk posed to the entity by theone or more updated risk triggers; and (6) updating the risk remediationdata to include the one or more updated actions to remediate the risk inresponse to identifying the one or more updated risk triggers.

A computer-implemented method for updating risk remediation data of anentity, in particular embodiments, comprises: (1) receiving anindication of an update to the first data asset of the entity receivingan indication of an update to the first data asset of the entity; (2)identifying one or more risk triggers for an entity based at least inpart on the update to the first data asset of the entity; (3)identifying a second data asset of the entity potentially affected bythe one or more risk triggers based at least in part on an associationof the first data asset and the second data asset; (4) determining, byusing one or more data models, one or more first updated actions toremediate the one or more updated risk triggers for the first dataasset; (5) determining, by using one or more data models, one or moresecond updated actions to remediate the one or more updated risktriggers for the second data asset; and (6) generating risk remediationdata of the entity to include the one or more first updated actions andthe one or more second updated actions to remediate the one or morepotential risk triggers.

A computer-implemented method for generating risk remediation data foran entity, in particular embodiments, comprises: (1) accessing aggregaterisk remediation data for a plurality of identified risk triggers fromone or more organizations; (2) analyzing the aggregate risk remediationdata to determine a remediation outcome for each of the plurality ofidentified risk triggers and an associated entity response to theparticular identified risk trigger of the plurality of identified risktriggers; (3) in response to analyzing the aggregate risk remediationdata to determine a remediation outcome for each of the plurality ofidentified risk triggers and an associated entity response to theparticular identified risk trigger of the plurality of identified risktriggers, generating one or more risk remediation data models; and (4)generating risk remediation data for the entity based at least in parton the one or more risk remediation data models and one or more dataassets of the entity.

Various embodiments are also described in the following listing ofconcepts:

1. A computer-implemented data processing method for updating riskremediation data for an entity, the method comprising:

accessing risk remediation data for an entity that identifies one ormore actions to remediate a risk in response to identifying one or moredata assets of the entity potentially affected by one or more risktriggers;

receiving an indication of an update to the one or more data assets;

identifying one or more updated risk triggers for an entity based atleast in part on the update to the one or more data assets;

determining, by using one or more data models associated with the riskremediation data, one or more updated actions to remediate the one ormore updated risk triggers;

analyzing the one or more updated risk triggers to determine a relevanceof the risk posed to the entity by the one or more updated risktriggers; and

updating the risk remediation data to include the one or more updatedactions to remediate the risk in response to identifying the one or moreupdated risk triggers.

2. The computer-implemented data processing method of Concept 1, furthercomprising:

determining, based at least in part on the one or more data assets andthe relevance of the risk, whether to take one or more updated actionsin response to the one or more updated risk triggers; and

taking the one or more updated actions to remediate the risk in responseto identifying the one or more updated risk triggers.

3. The computer-implemented data processing method of Concept 1, whereinupdating the risk remediation data is performed automatically.

4. The computer-implemented data processing method of Concept 1, whereinthe one or more updated risk triggers comprises the one or more dataassets being physically located in one or more particular locations.

5. The computer-implemented data processing method of Concept 4, whereinthe one or more particular locations comprise a single physicallocation.

6. The computer-implemented data processing method of Concept 1, whereinanalyzing the one or more updated risk triggers to determine therelevance of the risk posed to the entity by the one or more updatedrisk triggers further comprises:

calculating a risk level based at least in part on the one or moreupdated risk triggers;

in response to calculating the risk level, comparing the risk level to athreshold risk level for the entity; and

in response to determining that the risk level is greater than or equalto the threshold risk level, updating the risk remediation data toinclude the one or more updated actions to remediate the risk inresponse to identifying the one or more updated risk triggers.

7. The computer-implemented data processing method of Concept 6, whereincalculating the risk level based at least in part on the one or moreupdated risk triggers further comprises comparing the one or moreupdated risk triggers to (i) one or more previously identified risktriggers, and (ii) one or more previously implemented actions to the oneor more previously identified risk triggers.

8. The computer-implemented data processing method of Concept 1, themethod further comprising generating at least one data model of the oneor more data models by:

receiving aggregate risk remediation data for a plurality of identifiedrisk triggers from one or more organizations;

analyzing the aggregate risk remediation data to determine a remediationoutcome for each of the plurality of identified risk triggers and anassociated entity response to the particular identified risk trigger ofthe plurality of identified risk triggers; and

in response to analyzing the aggregate risk remediation data todetermine a remediation outcome for each of the plurality of identifiedrisk triggers and an associated entity response to the particularidentified risk trigger of the plurality of identified risk triggers,generating the at least one data model of the one or more data models.

9. The computer-implemented data processing method of Concept 8, whereinthe risk remediation data implements the at least one data model of theone or more data models.

10. The computer-implemented data processing method of Concept 8,wherein the one or more organizations comprises the entity.

11. A computer-implemented data processing method for updating riskremediation data of an entity, the method comprising:

receiving an indication of an update to the first data asset of theentity;

identifying one or more risk triggers for an entity based at least inpart on the update to the first data asset of the entity;

identifying a second data asset of the entity potentially affected bythe one or more risk triggers based at least in part on an associationof the first data asset and the second data asset;

determining, by using one or more data models, one or more first updatedactions to remediate the one or more updated risk triggers for the firstdata asset;

determining, by using one or more data models, one or more secondupdated actions to remediate the one or more updated risk triggers forthe second data asset; and

generating risk remediation data of the entity to include the one ormore first updated actions and the one or more second updated actions toremediate the one or more potential risk triggers.

12. The computer-implemented data processing method of Concept 11,further comprising:

determining a first data asset risk level based at least in part on theone or more updated risk triggers for the first data asset;

determining to take the one or more first updated actions to remediatethe one or more updated risk triggers for the first data asset based atleast in part on the first data asset risk level; and

in response, taking the first updated actions to remediate the one ormore updated risk triggers for the first data asset.

13. The computer-implemented data processing method of Concept 12,further comprising:

comparing the first data asset risk level to a threshold data asset risklevel; and

in response to determining that the first data asset risk level isgreater than or equal to the threshold data asset risk level, taking thefirst updated actions to remediate the one or more updated risk triggersfor the first data asset.

14. The computer-implemented data processing method of Concept 11,wherein the one or more first updated actions to remediate the one ormore updated risk triggers for the first data asset is the one or moresecond updated actions to remediate the one or more updated risktriggers for the second data asset.

15. The computer-implemented data processing method of Concept 11,wherein the one or more first updated actions to remediate the one ormore updated risk triggers for the first data asset is different fromthe one or more second updated actions to remediate the one or moreupdated risk triggers for the second data asset.

16. The computer-implemented data processing method of Concept 11,wherein generating the risk remediation data of the entity to includethe one or more first updated actions and the one or more second updatedactions to remediate the one or more potential risk triggers isperformed automatically.

17. The computer-implemented data processing method of Concept 11,wherein the one or more risk triggers comprises one or more of the firstdata asset and the second data asset being physically located in aparticular one or more locations.

18. The computer-implemented data processing method of Concept 17,wherein the one or more risk triggers comprises the first data assetbeing located in a first physical location and the second data assetbeing located in the first physical location.

19. A computer-implemented data processing method for generating riskremediation data for an entity, the method comprising:

accessing aggregate risk remediation data for a plurality of identifiedrisk triggers from one or more organizations;

analyzing the aggregate risk remediation data to determine a remediationoutcome for each of the plurality of identified risk triggers and anassociated entity response to the particular identified risk trigger ofthe plurality of identified risk triggers;

in response to analyzing the aggregate risk remediation data todetermine a remediation outcome for each of the plurality of identifiedrisk triggers and an associated entity response to the particularidentified risk trigger of the plurality of identified risk triggers,generating one or more risk remediation data models; and

generating risk remediation data for the entity based at least in parton the one or more risk remediation models and one or more data assetsof the entity.

20. The computer-implemented data processing method of Concept 19,further comprising updating the generated risk remediation dataautomatically.

A computer-implemented method for managing a plurality of data assets ofan organization with a third-party data repository, in particularembodiments, comprises: (1) identifying a form used to collect one ormore pieces of personal data; (2) determining one or more data assets ofa plurality of data assets of the organization where input data of theform is transmitted; (3) adding the one or more data assets to thethird-party data repository with an electronic link to the form; (4) inresponse to a user submitting the form, creating a unique subjectidentifier associated with the user; (5) transmitting the unique subjectidentifier (i) to the third-party data repository and (ii) along withthe form data provided by the user in the form, to the data asset; and(6) digitally storing the unique subject identifier (i) in thethird-party data repository and (ii) along with the form data providedby the user in the form, in the data asset.

A computer-implemented method for or managing a plurality of data assetsof an organization with a unique subject identifier database, inparticular embodiments, comprises: (1) receiving an indication ofcompletion of a form associated with the organization by a data subject;(2) determining, based at least in part on searching a unique subjectidentifier database, whether a unique subject identifier has beengenerated for the data subject; (3) in response to determining that aunique subject identifier has not been generated for the data subject,generating a unique subject identifier for the data subject; and (4)storing the unique subject identifier for the data subject in the uniquesubject identifier database, wherein the unique subject identifierdatabase electronically links each respective unique subject identifierto each of: (i) the form associated with the organization submitted bythe data subject of each respective unique subject identifier, and (ii)one or more data assets that utilize form data of the form received fromthe data subject.

A computer-implemented method for managing a plurality of data assets ofan organization with a unique subject identifier database that, inparticular embodiments, comprises: (1) receiving an indication ofcompletion of a form associated with the organization by a data subject;(2) determining, based at least in part on searching a unique subjectidentifier database, whether a unique subject identifier has beengenerated for the data subject; (3) in response to determining that aunique subject identifier has been generated for the data subject,accessing the unique subject identifier database; (4) identifying theunique subject identifier of the data subject based at least in part onform data provided by the data subject in the completion of the formassociated with the organization; and (5) updating the unique subjectidentifier database to include an electronic link between the uniquesubject identifier of the data subject and each of (i) the formsubmitted by the data subject of each respective unique subjectidentifier, and (ii) one or more data assets that utilize the form dataof the form received from the data subject.

Various embodiments are also described in the following listing ofconcepts:

1. A computer-implemented data processing method for managing aplurality of data assets of an organization shared with a third-partydata repository, the method comprising:

identifying a form used to collect one or more pieces of personal data;

determining one or more data assets of a plurality of data assets of theorganization where input data of the form is transmitted;

adding the one or more data assets to the third-party data repositorywith an electronic link to the form;

in response to a user submitting the form, creating a unique subjectidentifier associated with the user;

transmitting the unique subject identifier to the third-party datarepository along with the form data provided by the user in the form, tothe data asset; and

digitally storing the unique subject identifier in the third-party datarepository and along with the form data provided by the user in theform, in the data asset.

2. The computer-implemented data processing method of Concept 1, furthercomprising:

receiving a data subject access request from the user;

accessing the third-party data repository to identify the unique subjectidentifier of the user;

determining which one or more data assets of the plurality of dataassets of the organization include the unique subject identifier; and

accessing personal data of the user stored in each of the one or moredata assets of the plurality of data assets of the organization thatinclude the unique subject identifier.

3. The computer-implemented data processing method of Concept 2, whereinthe data subject access request comprises a type of data subject accessrequest, and wherein the type of data subject access request is selectedfrom a group consisting of:

a subject's rights request, and a data subject deletion request.

4. The computer-implemented data processing method of Concept 3, whereinthe type of data subject access request is a data subject deletionrequest and further comprising:

in response to accessing the personal data of the user stored in each ofthe one or more data assets of the plurality of data assets of theorganization that include the unique subject identifier, deleting thepersonal data of the user stored in each of the one or more data assetsof the plurality of data assets of the organization that include theunique subject identifier.

5. The computer-implemented data processing method of Concept 3, whereinthe type of data subject access request is a data subject deletionrequest and the method further comprises:

in response to accessing the personal data of the user stored in each ofthe one or more data assets of the plurality of data assets,automatically determining that a first portion of personal data of theuser stored in the one or more data assets has one or more legal basesfor continued storage;

in response to determining that the first portion of personal data ofthe user stored in the one or more data assets has one or more legalbases for continued storage, automatically maintaining storage of thefirst portion of personal data of the user stored in the one or moredata assets;

automatically facilitating deletion of a second portion of personal dataof the user stored in the one or more data assets for which one or morelegal bases for continued storage cannot be determined, wherein thefirst portion of the personal data of the user stored in the one or moredata assets is different from the second portion of personal data of theuser stored in the one or more data assets; and

automatically marking as free one or more memory addresses associatedwith the second portion of personal data of the user stored in the oneor more data assets associated with the user.

6. The computer-implemented data processing method of Concept 1, whereinidentifying a form used to collect one or more pieces of personal datais performed by using one or more web site scanning tools.

7. The computer-implemented data processing method of Concept 1, whereinthe third-party data repository comprises a link to each of the one ormore data assets of the plurality of data assets of the organizationthat include the unique subject identifier of the user.

8. The computer-implemented data processing of Concept 1, wherein thethird-party data repository stores the unique subject identifier in adatabase of a plurality of unique subject identifiers.

9. A computer-implemented data processing method for managing aplurality of data assets of an organization with a unique subjectidentifier database, the method comprising:

receiving an indication of completion of a form associated with theorganization by a data subject;

determining, based at least in part on searching a unique subjectidentifier database, whether a unique subject identifier has beengenerated for the data subject;

in response to determining that a unique subject identifier has not beengenerated for the data subject, generating a unique subject identifierfor the data subject; and

storing the unique subject identifier for the data subject in the uniquesubject identifier database, wherein the unique subject identifierdatabase electronically links each respective unique subject identifierto each of: (i) the form associated with the organization submitted bythe data subject of each respective unique subject identifier, and (ii)one or more data assets that utilize form data of the form received fromthe data subject.

10. The computer-implemented data processing method of Concept 9,further comprising:

receiving a data subject access request from the data subject;

accessing the unique subject identifier database to identify the uniquesubject identifier of the data subject;

determining which one or more data assets of the plurality of dataassets of the organization include the unique subject identifier of thedata subject; and

accessing personal data of the data subject stored in each of the one ormore data assets of the plurality of data assets of the organizationthat include the unique subject identifier.

11. The computer-implemented data processing method of Concept 10,wherein the data subject access request comprises a type of data subjectaccess request, and wherein the type of data subject access request isselected from a group consisting of:

a subject's rights request, and

a data subject deletion request.

12. The computer-implemented data processing method of Concept 11,wherein the type of data subject access request is a data subjectdeletion request and further comprising:

in response to accessing the personal data of the data subject stored ineach of the one or more data assets of the plurality of data assets ofthe organization that include the unique subject identifier, deletingthe personal data of the data subject stored in each of the one or moredata assets of the plurality of data assets of the organization thatinclude the unique subject identifier.

13. The computer-implemented data processing method of Concept 9,further comprising:

in response to determining that a unique subject identifier has beengenerated for the data subject, accessing the unique subject identifierdatabase; and

identifying the unique subject identifier of the data subject based atleast in part on form data provided by the data subject in thecompletion of the form associated with the organization.

14. The computer-implemented data processing method of Concept 13,further comprising:

updating the unique subject identifier database to include an electroniclink between the unique subject identifier of the data subject and eachof (i) the form submitted by the data subject of each respective uniquesubject identifier, and (ii) one or more data assets that utilize theform data of the form received from the data subject.

15. A computer-implemented data processing method for managing aplurality of data assets of an organization with a unique subjectidentifier database, the method comprising:

receiving an indication of completion of a form associated with theorganization by a data subject;

determining, based at least in part on searching a unique subjectidentifier database, whether a unique subject identifier has beengenerated for the data subject;

in response to determining that a unique subject identifier has beengenerated for the data subject, accessing the unique subject identifierdatabase;

identifying the unique subject identifier of the data subject based atleast in part on form data provided by the data subject in thecompletion of the form associated with the organization;

and updating the unique subject identifier database to include anelectronic link between the unique subject identifier of the datasubject and each of (i) the form submitted by the data subject of eachrespective unique subject identifier, and (ii) one or more data assetsthat utilize the form data of the form received from the data subject.

16. The computer-implemented data processing method of Concept 15,further comprising:

receiving a data subject access request from the data subject;

accessing the unique subject identifier database to identify the uniquesubject identifier of the data subject;

determining which one or more data assets of the plurality of dataassets of the organization include the unique subject identifier of thedata subject; and

accessing personal data of the data subject stored in each of the one ormore data assets of the plurality of data assets of the organizationthat include the unique subject identifier.

17. The computer-implemented data processing method of Concept 16,wherein the data subject access request comprises a type of data subjectaccess request, and wherein the type of data subject access request isselected from a group consisting of:

a subject's rights request, and

a data subject deletion request.

18. The computer-implemented data processing method of Concept 17,wherein the type of data subject access request is a data subjectdeletion request and further comprising:

in response to accessing the personal data of the data subject stored ineach of the one or more data assets of the plurality of data assets ofthe organization that include the unique subject identifier, deletingthe personal data of the data subject stored in each of the one or moredata assets of the plurality of data assets of the organization thatinclude the unique subject identifier.

19. The computer-implemented data processing method of Concept 17,wherein the type of data subject access request is a data subjectdeletion request and the method further comprises:

in response to accessing the personal data of the data subject stored ineach of the one or more data assets of the plurality of data assets,automatically determining that a first portion of personal data of thedata subject stored in the one or more data assets has one or more legalbases for continued storage;

in response to determining that the first portion of personal data ofthe data subject stored in the one or more data assets has one or morelegal bases for continued storage, automatically maintaining storage ofthe first portion of personal data of the data subject stored in the oneor more data assets;

automatically facilitating deletion of a second portion of personal dataof the data subject stored in the one or more data assets for which oneor more legal bases for continued storage cannot be determined, whereinthe first portion of the personal data of the data subject stored in theone or more data assets is different from the second portion of personaldata of the data subject stored in the one or more data assets; and

automatically marking one or more memory addresses associated with thesecond portion of personal data of the data subject stored in the one ormore data assets associated with the data subject as free.

20. The computer-implemented data processing of Concept 1, wherein theunique subject identifier database is a part of a third-party datarepository.

A computer-implemented method for assessing a risk associated with oneor more data transfers between one or more data assets (e.g., two ormore data assets), in particular embodiments, comprises: (1) creating adata transfer record for a data transfer between a first asset in afirst location and a second asset in a second location; (2) accessing aset of data transfer rules that are associated with the data transferrecord; (3) performing a data transfer assessment based at least in parton applying the set of data transfer rules on the data transfer record;(4) identifying one or more data transfer risks associated with the datatransfer record, based at least in part on the data transfer assessment;(5) calculating a risk score for the data transfer based at least inpart on the one or more data transfer risks associated with the datatransfer record; and (6) digitally storing the risk score for the datatransfer.

A computer-implemented method for assessing a risk associated with oneor more data transfers between one or more data assets, in particularembodiments, comprises: (1) accessing a data transfer record for a datatransfer between a first asset in a first location and a second asset ina second location; (2) accessing a set of data transfer rules that areassociated with the data transfer record, wherein the set of datatransfer rules comprise (a) one or more privacy law framework of the oneor more of the first location and the second location, and (b) one ormore entity framework of one or more of (i) an entity associated withthe one or more first data asset and (ii) an entity associated with theone or more second data asset; (3) performing a data transfer assessmentbased at least in part on applying the set of data transfer rules on thedata transfer record; (4) identifying one or more data transfer risksassociated with the data transfer record, based at least in part on thedata transfer assessment; (5) calculating a risk score for the datatransfer based at least in part on the one or more data transfer risksassociated with the data transfer record; and (6) digitally storing therisk score for the data transfer.

A computer-implemented method for assessing a risk associated with oneor more data transfers between one or more data assets, in particularembodiments, comprises: (1) accessing a data transfer record for a datatransfer between a first asset in a first location and a second asset ina second location; (2) accessing a set of data transfer rules that areassociated with the data transfer record; (3) performing a data transferassessment based at least in part on applying the set of data transferrules on the data transfer record; (4) identifying one or more datatransfer risks associated with the data transfer record, based at leastin part on the data transfer assessment; (5) calculating a risk scorefor the data transfer based at least in part on the one or more datatransfer risks associated with the data transfer record; (6) digitallystoring the risk score for the data transfer; (7) comparing the riskscore for the data transfer to a threshold risk score; (8) determiningthat the risk score for the data transfer is a greater risk than thethreshold risk score; and (9) in response to determining that the riskscore for the data transfer is a greater risk than the threshold riskscore, taking one or more action.

Various embodiments are also described in the following listing ofconcepts:

1. A computer-implemented data processing method for assessing a riskassociated with one or more data transfers between one or more dataassets, the method comprising:

creating a data transfer record for a data transfer between a firstasset in a first location and a second asset in a second location;

accessing a set of data transfer rules that are associated with the datatransfer record;

performing a data transfer assessment based at least in part on applyingthe set of data transfer rules on the data transfer record;

identifying one or more data transfer risks associated with the datatransfer record, based at least in part on the data transfer assessment;

calculating a risk score for the data transfer based at least in part onthe one or more data transfer risks associated with the data transferrecord; and

digitally storing the risk score for the data transfer.

2. The computer-implemented data processing method of Concept 1, whereinthe method further comprises:

comparing the risk score for the data transfer to a threshold riskscore;

determining that the risk score for the data transfer is a greater riskthan the threshold risk score; and

in response to determining that the risk score for the data transfer isa greater risk than the threshold risk score, taking one or more action.

3. The computer-implemented data processing method of Concept 2, whereinthe one or more action is selected from a group consisting of:

providing the data transfer record to one or more individuals for reviewof the data transfer record; and

automatically terminating the data transfer.

4. The computer-implemented data processing method of Concept 2, whereinthe one or more action comprises:

generating a secure link between one or more processors associated withthe first asset in the first location and one or more processorsassociated with the second asset in the second location; and

providing the data transfer via the secure link between the one or moreprocessors associated with the first asset in the first location and theone or more processors associated with the second asset in the secondlocation.

5. The computer-implemented data processing method of Concept 1, whereincalculating a risk score for the data transfer based at least in part onthe one or more data transfer risks associated with the data transferrecord further comprises:

determining a weighting factor for each of the one or more data transferrisks;

determining a risk rating for each of the one or more data transferrisks; and

calculating the risk level for the data transfer based upon, for eachrespective one of the one or more data transfer risks, the risk ratingfor the respective data transfer risk and the weighting factor for therespective data transfer risk.

6. The computer-implemented data processing method of Concept 1, whereinthe one or more data transfer risks are selected from a group consistingof:

a source location of the first location of the one or more first dataasset of the data transfer;

a destination location of the second location of the one or more seconddata asset of the data transfer;

one or more type of data being transferred as part of the data transfer;

a time of the data transfer; and

an amount of data being transferred as part of the data transfer.

7. The computer-implemented data processing method of Concept 1, whereinthe set of data transfer rules are automatically updated.

8. The computer-implemented data processing method of Concept 1, whereinthe set of data transfer rules comprise:

one or more privacy law framework of the one or more of the firstlocation and the second location; and

one or more entity framework of one or more of (i) an entity associatedwith the one or more first data asset and (ii) an entity associated withthe one or more second data asset.

9. A computer-implemented data processing method for assessing a riskassociated with one or more data transfers between one or more dataassets, the method comprising:

accessing a data transfer record for a data transfer between a firstasset in a first location and a second asset in a second location;

accessing a set of data transfer rules that are associated with the datatransfer record, wherein the set of data transfer rules comprise:

-   -   one or more privacy law framework of the one or more of the        first location and the second location, and    -   one or more entity framework of one or more of (i) an entity        associated with the one or more first data asset and (ii) an        entity associated with the one or more second data asset;

performing a data transfer assessment based at least in part on applyingthe set of data transfer rules on the data transfer record;

identifying one or more data transfer risks associated with the datatransfer record, based at least in part on the data transfer assessment;

calculating a risk score for the data transfer based at least in part onthe one or more data transfer risks associated with the data transferrecord; and

digitally storing the risk score for the data transfer.

10. The computer-implemented data processing method of Concept 9,wherein the method further comprises:

comparing the risk score for the data transfer to a threshold riskscore;

determining that the risk score for the data transfer is a greater riskthan the threshold risk score; and

in response to determining that the risk score for the data transfer isa greater risk than the threshold risk score, taking one or more action.

11. The computer-implemented data processing method of Concept 10,wherein the one or more action is selected from a group consisting of:

providing the data transfer record to one or more individuals for reviewof the data transfer record; and

automatically terminating the data transfer.

12. The computer-implemented data processing method of Concept 10,wherein the one or more action comprises:

generating a secure link between one or more processors associated withthe first asset in the first location and one or more processorsassociated with the second asset in the second location; and

providing the data transfer via the secure link between the one or moreprocessors associated with the first asset in the first location and theone or more processors associated with the second asset in the secondlocation.

13. The computer-implemented data processing method of Concept 9,wherein calculating a risk score for the data transfer based at least inpart on the one or more data transfer risks associated with the datatransfer record further comprises:

determining a weighting factor for each of the one or more data transferrisks;

determining a risk rating for each of the one or more data transferrisks; and

calculating the risk level for the data transfer based upon, for eachrespective one of the one or more data transfer risks, the risk ratingfor the respective data transfer risk and the weighting factor for therespective data transfer risk.

14. The computer-implemented data processing method of Concept 9,wherein the one or more data transfer risks are selected from a groupconsisting of:

a source location of the first location of the one or more first dataasset of the data transfer;

a destination location of the second location of the one or more seconddata asset of the data transfer;

one or more type of data being transferred as part of the data transfer;

a time of the data transfer; and

an amount of data being transferred as part of the data transfer.

15. The computer-implemented data processing method of Concept 9,wherein the set of data transfer rules are automatically updated.

16. A computer-implemented data processing method for assessing a riskassociated with one or more data transfers between one or more dataassets, the method comprising:

accessing a data transfer record for a data transfer between a firstasset in a first location and a second asset in a second location;

accessing a set of data transfer rules that are associated with the datatransfer record;

performing a data transfer assessment based at least in part on applyingthe set of data transfer rules on the data transfer record;

identifying one or more data transfer risks associated with the datatransfer record, based at least in part on the data transfer assessment;

calculating a risk score for the data transfer based at least in part onthe one or more data transfer risks associated with the data transferrecord;

digitally storing the risk score for the data transfer;

comparing the risk score for the data transfer to a threshold riskscore;

determining that the risk score for the data transfer is a greater riskthan the threshold risk score; and

in response to determining that the risk score for the data transfer isa greater risk than the threshold risk score, taking one or more action.

17. The computer-implemented data processing method of Concept 16,wherein the one or more action is selected from a group consisting of:

providing the data transfer record to one or more individuals for reviewof the data transfer record; and

automatically terminating the data transfer.

18. The computer-implemented data processing method of Concept 16,wherein the one or more data transfer risks are selected from a groupconsisting of:

a source location of the first location of the one or more first dataasset of the data transfer;

a destination location of the second location of the one or more seconddata asset of the data transfer;

one or more type of data being transferred as part of the data transfer;

a time of the data transfer; and

an amount of data being transferred as part of the data transfer.

19. The computer-implemented data processing method of Concept 16,wherein the one or more action comprises:

generating a secure link between one or more processors associated withthe first asset in the first location and one or more processorsassociated with the second asset in the second location; and

providing the data transfer via the secure link between the one or moreprocessors associated with the first asset in the first location and theone or more processors associated with the second asset in the secondlocation.

20. The computer-implemented data processing method of Concept 16,further comprising:

transferring the data between the first asset in the first location andthe second asset in the second location.

A computer-implemented data processing method for automaticallyclassifying personal information in an electronic document andgenerating a sensitivity score for the electronic document based on theclassification, in particular embodiments, comprises: (1) receiving, byone or more processors, the electronic document for analysis; (2) usingone or more natural language processing techniques, by one or moreprocessors, to decompose data from the electronic document into (i) oneor more structured objects and (ii) one or more values for each of theone or more structured objects; (3) classifying, by one or moreprocessors, each of the one or more structured objects in the electronicdocument based on one or more attributes of the one or more structuredobjects; (4) categorizing, by one or more processors, each of the one ormore structured objects based on a sensitivity of the one or morestructured objects; (5) rating, by one or more processors, the accuracyof the categorization; and (6) generating, by one or more processors, asensitivity score for the electronic document based at least in part onthe categorized one or more structured objects and the associated one ormore values.

A computer-implemented data processing method for automaticallyclassifying personal information in an electronic document andgenerating a sensitivity score for the electronic document based on theclassification, in particular embodiments, comprises: (1) receiving, byone or more processors, the electronic document for analysis; (2)sorting, using one or more natural language processing techniques, datafrom the electronic document into (i) one or more structured objects and(ii) one or more values for each of the one or more structured objects;(3) classifying, by one or more processors, each of the one or morestructured objects in the electronic document based on one or moreattributes of the one or more structured objects; (4) categorizing, byone or more processors, each of the one or more structured objects basedon a sensitivity of the one or more structured objects; (5) generating,by one or more processors, a sensitivity score for the electronicdocument based at least in part on the categorized one or morestructured objects and the associated one or more values; (6) parsingthe classification of one or more structured objects; (7) identifyingeach of the one or more structured objects having an empty associatedvalue; and (8) modifying the classification of one or more structuredobjects to remove the identified one or more structured objects from theclassification.

A computer-implemented data processing method for automaticallyclassifying personal information in an electronic document andgenerating a sensitivity score for the electronic document based on theclassification, in particular embodiments, comprises: (1) receiving, byone or more processors, the electronic document for analysis; (2) usingone or more natural language processing techniques, by one or moreprocessors, to decompose data from the electronic document into (i) oneor more structured objects and (ii) one or more values for each of theone or more structured objects; (3) classifying, by one or moreprocessors, each of the one or more structured objects in the electronicdocument based on one or more attributes of the one or more structuredobjects; (4) categorizing, by one or more processors, each of the one ormore structured objects based on a sensitivity of the one or morestructured objects; and (5) generating, by one or more processors, asensitivity score for the electronic document based at least in part onthe categorized one or more structured objects and the associated one ormore values.

Various embodiments are also described in the following listing ofconcepts:

1. A computer-implemented data processing method for automaticallyclassifying personal information in an electronic document andgenerating a sensitivity score for the electronic document based on theclassification, the method comprising:

receiving, by one or more processors, the electronic document foranalysis;

using one or more natural language processing techniques, by one or moreprocessors, to decompose data from the electronic document into:

-   -   one or more structured objects; and    -   one or more values for each of the one or more structured        objects;

classifying, by one or more processors, each of the one or morestructured objects in the electronic document based on one or moreattributes of the one or more structured objects;

categorizing, by one or more processors, each of the one or morestructured objects based on a sensitivity of the one or more structuredobjects;

rating, by one or more processors, the accuracy of the categorization;and

generating, by one or more processors, a sensitivity score for theelectronic document based at least in part on the categorized one ormore structured objects and the associated one or more values.

2. The computer-implemented data processing method of Concept 1, whereingenerating the sensitivity score for the electronic document comprises:

assigning a relative sensitivity rating to each of the one or morestructured objects; and

calculating the sensitivity score based on the one or more values andthe relative sensitivity rating for each of the one or more structuredobjects.

3. The computer-implemented data processing method of Concept 1, furthercomprising:

parsing the classification of one or more structured objects;

identifying each of the one or more structured objects having an emptyassociated value;

and modifying the classification of one or more structured objects toremove the identified one or more structured objects from theclassification.

4. The computer-implemented data processing method of Concept 1, whereinrating the accuracy of the categorization comprises:

receiving a second electronic document that is related to the electronicdocument;

using one or more natural language processing techniques, by one or moreprocessors, to decompose data from the second electronic document into;

-   -   one or more second structured objects; and    -   one or more second values for each of the one or more structured        objects;

classifying, by one or more processors, each of the one or more secondstructured objects in the second electronic document based on one ormore second attributes of the one or more second structured objects;

categorizing, by one or more processors, each of the one or more secondstructured objects based on a sensitivity of the one or more secondstructured objects; and

comparing the categorization of the one or more structured objects withthe categorization of the one or more second structured objects; and

rating the accuracy based on the comparison.

5. The computer-implemented data processing method of Concept 1, whereinthe one or more natural language process techniques is selected from agroup comprising:

one or more optical character recognition techniques; and

one or more audio processing techniques.

6. The computer-implemented data processing method of Concept 1, whereinthe one or more attributes of the one or more structured objectscomprise a position within the electronic document of each of the one ormore structured objects in the electronic document.

7. The computer-implemented data processing method of Concept 1, whereinthe sensitivity of the one or more structured objects is automaticallydetermined based at least in part on one or more government regulationsdirected toward the type of information associated with the particularone or more structured objects.

8. The computer-implemented data processing of Concept 1, wherein ratingthe accuracy of the categorization of each of the one or more structuredobjects further comprises:

determining a character type for each of the one or more structuredobjects;

determining a character type for each value associated with each of theone or more structured objects;

comparing the character type for each value associated with each of theone or more structured objects and the character type for each of theone or more structured objects; and

rating the accuracy of the categorization of each of the one or morestructured objects based at least in part on comparing the charactertype for each value associated with each of the one or more structuredobjects and the character type for each of the one or more structuredobjects.

9. A computer-implemented data processing method for automaticallyclassifying personal information in an electronic document andgenerating a sensitivity score for the electronic document based on theclassification, the method comprising:

receiving, by one or more processors, the electronic document foranalysis;

sorting, using one or more natural language processing techniques, datafrom the electronic document into;

-   -   one or more structured objects; and    -   one or more values for each of the one or more structured        objects;

classifying, by one or more processors, each of the one or morestructured objects in the electronic document based on one or moreattributes of the one or more structured objects;

categorizing, by one or more processors, each of the one or morestructured objects based on a sensitivity of the one or more structuredobjects;

generating, by one or more processors, a sensitivity score for theelectronic document based at least in part on the categorized one ormore structured objects and the associated one or more values;

parsing the classification of one or more structured objects;

identifying each of the one or more structured objects having an emptyassociated value;

and modifying the classification of one or more structured objects toremove the identified one or more structured objects from theclassification.

10. The computer-implemented data processing method of Concept 9,wherein generating the sensitivity score for the electronic documentcomprises:

assigning a relative sensitivity rating to each of the one or morestructured objects; and

calculating the sensitivity score based on the one or more values andthe relative sensitivity rating for each of the one or more structuredobjects.

11. The computer-implemented data processing method of Concept 1,wherein rating the accuracy of the categorization comprises:

receiving a second electronic document that is related to the electronicdocument;

sorting, using one or more natural language processing techniques, thesecond electronic document into;

-   -   one or more second structured objects; and    -   one or more second values for each of the one or more structured        objects;

classifying, by one or more processors, each of the one or more secondstructured objects in the second electronic document based on one ormore second attributes of the one or more second structured objects;

categorizing, by one or more processors, each of the one or more secondstructured objects based on a sensitivity of the one or more secondstructured objects; and

generating, by one or more processors, a second sensitivity score forthe second electronic document based at least in part on the categorizedone or more second structured objects and the associated one or moresecond values;

parsing the classification of one or more second structured objects;

identifying each of the one or more second structured objects having anempty associated value; and

modifying the classification of one or more second structured objects toremove the identified one or more second structured objects from theclassification.

12. The computer-implemented data processing method of Concept 9,wherein the one or more natural language process techniques is selectedfrom a group comprising:

one or more optical character recognition techniques; and

one or more audio processing techniques.

13. The computer-implemented data processing method of Concept 9,wherein the one or more attributes of the one or more structured objectscomprise a position within the electronic document of each of the one ormore structured objects in the electronic document.

14. The computer-implemented data processing method of Concept 9,wherein the sensitivity of the one or more structured objects isautomatically determined based at least in part on one or moregovernment regulations directed toward the type of informationassociated with the particular one or more structured objects.

15. A computer-implemented data processing method for automaticallyclassifying personal information in an electronic document andgenerating a sensitivity score for the electronic document based on theclassification, the method comprising:

receiving, by one or more processors, the electronic document foranalysis;

using one or more natural language processing techniques, by one or moreprocessors, to decompose data from the electronic document into;

-   -   one or more structured objects; and    -   one or more values for each of the one or more structured        objects;

classifying, by one or more processors, each of the one or morestructured objects in the electronic document based on one or moreattributes of the one or more structured objects;

categorizing, by one or more processors, each of the one or morestructured objects based on a sensitivity of the one or more structuredobjects; and

generating, by one or more processors, a sensitivity score for theelectronic document based at least in part on the categorized one ormore structured objects and the associated one or more values.

16. The computer-implemented data processing method of Concept 15,wherein generating the sensitivity score for the electronic documentcomprises:

assigning a relative sensitivity rating to each of the one or morestructured objects; and

calculating the sensitivity score based on the one or more values andthe relative sensitivity rating for each of the one or more structuredobjects.

17. The computer-implemented data processing method of Concept 15,wherein rating the accuracy of the categorization comprises:

receiving a second electronic document that is related to the electronicdocument;

using one or more natural language processing techniques, by one or moreprocessors, to decompose data from the second electronic document into;

-   -   one or more second structured objects; and    -   one or more second values for each of the one or more structured        objects;

classifying, by one or more processors, each of the one or more secondstructured objects in the second electronic document based on one ormore second attributes of the one or more second structured objects;

categorizing, by one or more processors, each of the one or more secondstructured objects based on a sensitivity of the one or more secondstructured objects; and

comparing the categorization of the one or more structured objects withthe categorization of the one or more second structured objects; and

rating the accuracy based on the comparison.

18. The computer-implemented data processing method of Concept 15,wherein the one or more natural language process techniques is selectedfrom a group comprising:

one or more optical character recognition techniques; and

one or more audio processing techniques.

19. The computer-implemented data processing method of Concept 15,wherein the one or more attributes of the one or more structured objectscomprise a position within the electronic document of each of the one ormore structured objects in the electronic document.

20. The computer-implemented data processing method of Concept 1,wherein the sensitivity of the one or more structured objects isautomatically determined based at least in part on one or moregovernment regulations directed toward the type of informationassociated with the particular one or more structured objects.

BRIEF DESCRIPTION OF THE DRAWINGS

Various embodiments of a data model generation and population system aredescribed below. In the course of this description, reference will bemade to the accompanying drawings, which are not necessarily drawn toscale, and wherein:

FIG. 1 depicts a data model generation and population system accordingto particular embodiments.

FIG. 2 is a schematic diagram of a computer (such as the data modelgeneration server 110, or data model population server 120) that issuitable for use in various embodiments of the data model generation andpopulation system shown in FIG. 1 .

FIG. 3 is a flowchart showing an example of steps performed by a DataModel Generation Module according to particular embodiments.

FIGS. 4-10 depict various exemplary visual representations of datamodels according to particular embodiments.

FIG. 11 is a flowchart showing an example of steps performed by a DataModel Population Module.

FIG. 12 is a flowchart showing an example of steps performed by a DataPopulation Questionnaire Generation Module.

FIG. 13 is a process flow for populating a data inventory according to aparticular embodiment using one or more data mapping techniques.

FIGS. 14-25 depict exemplary screen displays and graphical userinterfaces (GUIs) according to various embodiments of the system, whichmay display information associated with the system or enable access to,or interaction with, the system by one or more users (e.g., to configurea questionnaire for populating one or more inventory attributes for oneor more data models, complete one or more assessments, etc.).

FIG. 26 is a flowchart showing an example of steps performed by anIntelligent Identity Scanning Module.

FIG. 27 is schematic diagram of network architecture for an intelligentidentity scanning system 2700 according to a particular embodiment.

FIG. 28 is a schematic diagram of an asset access methodology utilizedby an intelligent identity scanning system 2700 in various embodimentsof the system.

FIG. 29 is a flowchart showing an example of processes performed by aData Subject Access Request Fulfillment Module 2900 according to variousembodiments.

FIGS. 30-31 depict exemplary screen displays and graphical userinterfaces (GUIs) according to various embodiments of the system, whichmay display information associated with the system or enable access to,or interaction with, the system by one or more users (e.g., for thepurpose of submitting a data subject access request or other suitablerequest).

FIGS. 32-35 depict exemplary screen displays and graphical userinterfaces (GUIs) according to various embodiments of the system, whichmay display information associated with the system or enable access to,or interaction with, the system by one or more users (e.g., for thepurpose of flagging one or more risks associated with one or moreparticular questionnaire questions).

FIG. 36 is a flowchart showing an example of processes performed by aCross-Border Visualization Generation Module 3600 according to variousembodiments.

FIGS. 37-38 depict exemplary screen displays and graphical userinterfaces (GUIs) according to various embodiments of the system, whichmay display information associated with the system or enable access to,or interaction with, the system by one or more users (e.g., related tocross-border visualization).

FIG. 39 is a flowchart showing an example of processes performed by anAdaptive Execution on a Data Model Module 3900 according to variousembodiments.

FIG. 40 depicts an exemplary screen display and graphical user interface(GUI) according to various embodiments of the system, which may displayinformation associated with the system or enable access to, orinteraction with, the system by one or more users.

FIG. 41 is a flowchart showing an example of processes performed by anE-mail Scanning Module 4100 according to various embodiments.

FIG. 42 depicts an exemplary screen display and graphical user interface(GUI) according to various embodiments of the system, which may displayinformation associated with the system or enable access to, orinteraction with, the system by one or more users.

FIG. 43 is a flowchart showing an example of processes performed by aWebform Crawling Module 4300 according to various embodiments.

FIG. 44 is a flowchart showing an example of processes performed by aData Asset and Webform Management Module 4400 according to yet anotherembodiment.

FIGS. 45-49 depict various exemplary screen displays and user interfacesthat a user of various embodiments of the system may encounter (FIGS. 47and 48 collectively show four different views of a Data Subject RequestQueue).

FIG. 50 is a flowchart showing an example of processes performed by anOrphaned Data Action Module 5000 according to various embodiments.

FIG. 51 is a flowchart showing an example of processes performed by aPersonal Data Deletion and Testing Module 5100 according to variousembodiments.

FIG. 52 is a flowchart showing an example of processes performed by aData Risk Remediation Module 5200 according to various embodiments.

FIG. 53 is a flowchart showing an example of processes performed by aCentral Consent Module 5300 according to various embodiments.

FIG. 54 is a flowchart showing an example of processes performed by aData Transfer Risk Identification Module 5400 according to variousembodiments.

FIG. 55 is a is a flowchart showing an example of a process performed byan Automated Classification Module 5500 according to particularembodiments.

FIG. 56 is a screenshot of a document from which the system describedherein may be configured to automatically classify personal information.

FIG. 57 depicts a visual representation of a plurality of objects thatthe system may create for each particular label identified in adocument.

FIGS. 58-60 depict a visual representation of the system creating aclassification and categorization of objects using contextualinformation from the document.

FIG. 61 depicts a visual representation of the system mapping valuesinto an object structure according to the classification andcategorization created as shown in FIGS. 57-59 .

FIG. 62 depicts a visual representation of the mapped results of anautomatic classification of personal information in a document describedherein.

DETAILED DESCRIPTION

Various embodiments now will be described more fully hereinafter withreference to the accompanying drawings. It should be understood that theinvention may be embodied in many different forms and should not beconstrued as limited to the embodiments set forth herein. Rather, theseembodiments are provided so that this disclosure will be thorough andcomplete, and will fully convey the scope of the invention to thoseskilled in the art. Like numbers refer to like elements throughout.

Overview

A data model generation and population system, according to particularembodiments, is configured to generate a data model (e.g., one or moredata models) that maps one or more relationships between and/or among aplurality of data assets utilized by a corporation or other entity(e.g., individual, organization, etc.) in the context, for example, ofone or more business processes. In particular embodiments, each of theplurality of data assets (e.g., data systems) may include, for example,any entity that collects, processes, contains, and/or transfers data(e.g., such as a software application, “internet of things” computerizeddevice, database, web site, data-center, server, etc.). For example, afirst data asset may include any software or device (e.g., server orservers) utilized by a particular entity for such data collection,processing, transfer, storage, etc.

As shown in FIGS. 4 and 5 , in various embodiments, the data model maystore the following information: (1) the organization that owns and/oruses a particular data asset (a primary data asset, which is shown inthe center of the data model in FIG. 4 ); (2) one or more departmentswithin the organization that are responsible for the data asset; (3) oneor more software applications that collect data (e.g., personal data)for storage in and/or use by the data asset (e.g., or one or more othersuitable collection assets from which the personal data that iscollected, processed, stored, etc. by the primary data asset issourced); (4) one or more particular data subjects (or categories ofdata subjects) that information is collected from for use by the dataasset; (5) one or more particular types of data that are collected byeach of the particular applications for storage in and/or use by thedata asset; (6) one or more individuals (e.g., particular individuals ortypes of individuals) that are permitted to access and/or use the datastored in, or used by, the data asset; (7) which particular types ofdata each of those individuals are allowed to access and use; and (8)one or more data assets (destination assets) that the data istransferred to for other use, and which particular data is transferredto each of those data assets. As shown in FIGS. 6 and 7 , the system mayalso optionally store information regarding, for example, which businessprocesses and processing activities utilize the data asset.

In particular embodiments, the data model stores this information foreach of a plurality of different data assets and may include linksbetween, for example, a portion of the model that provides informationfor a first particular data asset and a second portion of the model thatprovides information for a second particular data asset.

In various embodiments, the data model generation and population systemmay be implemented in the context of any suitable privacy managementsystem that is configured to ensure compliance with one or more legal orindustry standards related to the collection and/or storage of privateinformation. In various embodiments, a particular organization,sub-group, or other entity may initiate a privacy campaign or otheractivity (e.g., processing activity) as part of its business activities.In such embodiments, the privacy campaign may include any undertaking bya particular organization (e.g., such as a project or other activity)that includes the collection, entry, and/or storage (e.g., in memory) ofany personal data associated with one or more individuals. In particularembodiments, a privacy campaign may include any project undertaken by anorganization that includes the use of personal data, or any otheractivity that could have an impact on the privacy of one or moreindividuals.

In any embodiment described herein, personal data may include, forexample: (1) the name of a particular data subject (which may be aparticular individual); (2) the data subject's address; (3) the datasubject's telephone number; (4) the data subject's e-mail address; (5)the data subject's social security number; (6) information associatedwith one or more of the data subject's credit accounts (e.g., creditcard numbers); (7) banking information for the data subject; (8)location data for the data subject (e.g., their present or pastlocation); (9) internet search history for the data subject; and/or (10)any other suitable personal information, such as other personalinformation discussed herein. In particular embodiments, such personaldata may include one or more cookies (e.g., where the individual isdirectly identifiable or may be identifiable based at least in part oninformation stored in the one or more cookies).

In particular embodiments, when generating a data model, the system may,for example: (1) identify one or more data assets associated with aparticular organization; (2) generate a data inventory for each of theone or more data assets, where the data inventory comprises informationsuch as: (a) one or more processing activities associated with each ofthe one or more data assets, (b) transfer data associated with each ofthe one or more data assets (data regarding which data is transferredto/from each of the data assets, and which data assets, or individuals,the data is received from and/or transferred to, (c) personal dataassociated with each of the one or more data assets (e.g., particulartypes of data collected, stored, processed, etc. by the one or more dataassets), and/or (d) any other suitable information; and (3) populate thedata model using one or more suitable techniques.

In particular embodiments, the one or more techniques for populating thedata model may include, for example: (1) obtaining information for thedata model by using one or more questionnaires associated with aparticular privacy campaign, processing activity, etc.; (2) using one ormore intelligent identity scanning techniques discussed herein toidentify personal data stored by the system and map such data to asuitable data model, data asset within a data model, etc.; (3) obtaininginformation for the data model from a third-party application (or otherapplication) using one or more application programming interfaces (API);and/or (4) using any other suitable technique.

In particular embodiments, the system is configured to generate andpopulate a data model substantially on the fly (e.g., as the systemreceives new data associated with particular processing activities). Instill other embodiments, the system is configured to generate andpopulate a data model based at least in part on existing informationstored by the system (e.g., in one or more data assets), for example,using one or more suitable scanning techniques described herein.

As may be understood in light of this disclosure, a particularorganization may undertake a plurality of different privacy campaigns,processing activities, etc. that involve the collection and storage ofpersonal data. In some embodiments, each of the plurality of differentprocessing activities may collect redundant data (e.g., may collect thesame personal data for a particular individual more than once), and maystore data and/or redundant data in one or more particular locations(e.g., on one or more different servers, in one or more differentdatabases, etc.). In this way, a particular organization may storepersonal data in a plurality of different locations which may includeone or more known and/or unknown locations. By generating and populatinga data model of one or more data assets that are involved in thecollection, storage and processing of such personal data, the system maybe configured to create a data model that facilitates a straightforwardretrieval of information stored by the organization as desired. Forexample, in various embodiments, the system may be configured to use adata model in substantially automatically responding to one or more dataaccess requests by an individual (e.g., or other organization). In stillother embodiments, such data model generation and population may improvethe functionality of an entity's computing systems by enabling a morestreamlined retrieval of data from the system and eliminating redundantstorage of identical data. Various embodiments of a system forgenerating and populating a data model are described more fully below.

In particular embodiments, a Cross-Border Visualization GenerationSystem is configured to: (1) identify one or more data assets associatedwith a particular entity; (2) analyze the one or more data assets toidentify one or more data elements stored in the identified one or moredata assets; (3) define a plurality of physical locations and identify,for each of the identified one or more data assets, a respectiveparticular physical location of the plurality of physical locations; (4)analyze the identified one or more data elements to determine one ormore data transfers between the one or more data systems in differentparticular physical locations; (5) determine one or more regulationsthat relate to the one or more data transfers; and (6) generate a visualrepresentation of the one or more data transfers based at least in parton the one or more regulations.

In various embodiments, a Data Model Adaptive Execution System may beconfigured to take one or more suitable actions to remediate anidentified risk trigger in view of one or more regulations (e.g., one ormore legal regulations, one or more binding corporate rules, etc.). Forexample, in order to ensure compliance with one or more legal orindustry standards related to the collection and/or storage of privateinformation (e.g., personal data), an entity may be required to modifyone or more aspects of a way in which the entity collects, stores,and/or otherwise processes personal data (e.g., in response to a changein a legal or other requirement). In order to identify whether aparticular change or other risk trigger requires remediation, the systemmay be configured to assess a relevance of the risk posed by thepotential risk trigger and identify one or more processing activities ordata assets that may be affected by the risk.

The system may, for example: (1) identify and/or detect one or morepotential risk triggers; (2) assess and analyze the potential risktriggers to determine a relevance of the risk posed by the risktriggers; (3) use data modelling techniques to identify particularprocessing activities and/or data assets that may be affected by therisk; (4) determine based on a relevance of the risk and the affectedsystems/processes whether to take one or more actions; and (5) take asuitable action in response to the risk triggers, if necessary.

The risk triggers may include, for example a change in legal or industrystandards/regulations related to the collection, storage, and/orprocessing of personal data, a data breach, or any other suitable risktrigger. The suitable actions to remediate the risk may include, forexample, generating a report and providing it to a privacy officer orother individual, automatically modifying an encryption level ofparticular data stored by the system, quarantining particular data, etc.

In various embodiments, a system may be configured to substantiallyautomatically determine whether to take one or more actions in responseto one or more identified risk triggers (e.g., data breaches, changes inregulations, etc.). For example, the system may substantiallyautomatically determine a relevance of a risk posed by (e.g., a risklevel) the one or more potential risk triggers based at least in part onone or more previously-determined responses to similar risk triggers.This may include, for example, one or more previously determinedresponses for the particular entity that has identified the current risktrigger, one or more similarly situated entities, or any other suitableentity or potential trigger.

The system may, for example: (1) compare the potential risk trigger toone or more previous risks triggers experienced by the particular entityat a previous time; (2) identify a similar previous risk trigger (e.g.,one or more previous risk triggers related to a similar change inregulation, breach of data, type of issue identified, etc.); (3)determine the relevance of the current risk trigger based at least inpart on a determined relevance of the previous risk trigger; and (4)determine whether to take one or more actions to the current risktrigger based at least in part on one or more determined actions to takein response to the previous, similar risk trigger.

Similarly, in particular embodiments, the system may be configured tosubstantially automatically determine one or more actions to take inresponse to a current potential risk trigger based on one or moreactions taken by one or more similarly situated entities to one or moreprevious, similar risk triggers. For example, the system may beconfigured to: (1) compare the potential risk trigger to one or moreprevious risk triggers experienced by one or more similarly situatedentities at a previous time; (2) identify a similar previous risktrigger (e.g., one or more previous risk triggers related to a similarchange in regulation, breach of data, and/or type of issue identified,etc. from the one or more previous risk triggers experienced by the oneor more similarly-situated entities at the previous time; (3) determinethe relevance of the current risk trigger based at least in part on adetermined relevance of the previous risk trigger (e.g., a relevancedetermined by the one or more similarly situated entities); and (4)determine one or more actions to take in response to the current risktrigger based at least in part on one or more previously determinedactions to take in response to the previous, similar risk trigger (e.g.,one or more determined actions by the one or more similarly situatedentities at the previous time).

In particular embodiments, a Data Access Webform Crawling System isconfigured to: (1) identify a webform used to collect one or more piecesof personal data; (2) robotically complete the identified webform; (3)analyze the completed webform to determine one or more processingactivities that utilize the one or more pieces of personal datacollected by the webform; (4) identify a first data asset in the datamodel that is associated with the one or more processing activities; (5)modify a data inventory for the first data asset in the data model toinclude data associated with the webform; and (6) modify the data modelto include the modified data inventory for the first data asset.

In addition, various systems and computer-implemented methods aredescribed for: (1) analyzing electronic correspondence associated with adata subject (e.g., the emails within one or more email in-boxesassociated with the data subject); (2) based on the analysis,identifying one or more entities (e.g., corporate entities) that thatthe data subject does not actively do business with (e.g., as evidencedby the fact that the data subject no longer opens emails from theentity, or has set up a rule to automatically delete emails receivedfrom the entity); (3) in response to identifying the entity as an entitythat the data subject no longer actively does business with, at leastsubstantially automatically generating a data subject access requestand, optionally, automatically submitting the data subject accessrequest to the entity.

The system may, for example, be configured to determine whether the datasubject actively does business with a particular entity (e.g., purchasesproducts from, or uses one or more services from the entity) based atleast in part on one more determined interactions of the data subjectwith one or more e-mails, or other electronic correspondence, from theentity (e.g., whether the data subject reads the one or more e-mails,selects one or more links within the e-mails, deletes the e-mailswithout reading them, has set up a rule to auto-delete emails from theentity, has set up a rule to re-route emails from the entity to aparticular folder, or other location, designated for promotionalmaterials (e.g., unwanted promotional materials), and/or has set up arule to associate emails from the entity with metadata indicating thatthe correspondence is promotional in nature or should be re-routed orauto-deleted. The system may then substantially automatically generateand/or submit a data subject access request on behalf of the datasubject that includes a request to be forgotten (e.g., a request for theentity to delete some or all of the data subject's personal data thatthe entity is processing).

In particular embodiments, any entity (e.g., organization, company,etc.) that collects, stores, processes, etc. personal data may requireone or more of: (1) consent from a data subject from whom the personaldata is collected and/or processed; and/or (2) a lawful basis for thecollection and/or processing of the personal data. In variousembodiments, the entity may be required to, for example, demonstratethat a data subject has freely given specific, informed, and unambiguousindication of the data subject's agreement to the processing of his orher personal data for one or more specific purposes (e.g., in the formof a statement or clear affirmative action). As such, in particularembodiments, an organization may be required to demonstrate a lawfulbasis for each piece of personal data that the organization hascollected, processed, and/or stored. In particular, each piece ofpersonal data that an organization or entity has a lawful basis tocollect and process may be tied to a particular processing activityundertaken by the organization or entity.

A particular organization may undertake a plurality of different privacycampaigns, processing activities, etc. that involve the collection andstorage of personal data. In some embodiments, each of the plurality ofdifferent processing activities may collect redundant data (e.g., maycollect the same personal data for a particular individual more thanonce), and may store data and/or redundant data in one or moreparticular locations (e.g., on one or more different servers, in one ormore different databases, etc.). In this way, because of the number ofprocessing activities that an organization may undertake, and the amountof data collected as part of those processing activities over time, oneor more data systems associated with an entity or organization may storeor continue to store data that is not associated with any particularprocessing activity (e.g., any particular current processing activity).Under various legal and industry standards related to the collection andstorage of personal data, the organization or entity may not have or mayno longer have a legal basis to continue to store the data. As such,organizations and entities may require improved systems and methods toidentify such orphaned data, and take corrective action, if necessary(e.g., to ensure that the organization may not be in violation of one ormore legal or industry regulations).

In various embodiments, an orphaned personal data identification systemmay be configured to generate a data model (e.g., one or more datamodels) that maps one or more relationships between and/or among aplurality of data assets utilized by a corporation or other entity(e.g., individual, organization, etc.) in the context, for example, ofone or more business processes or processing activities. In particularembodiments, the system is configured to generate and populate a datamodel substantially on the fly (e.g., as the system receives new dataassociated with particular processing activities). In still otherembodiments, the system is configured to generate and populate a datamodel based at least in part on existing information stored by thesystem (e.g., in one or more data assets), for example, using one ormore suitable scanning techniques. In still other embodiments, thesystem is configured to access an existing data model that maps personaldata stored by one or more organization systems to particular associatedprocessing activities.

In various embodiments, the system may analyze the data model toidentify personal data that has been collected and stored using one ormore computer systems operated and/or utilized by a particularorganization where the personal data is not currently being used as partof any privacy campaigns, processing activities, etc. undertaken by theparticular organization. This data may be described as orphaned data. Insome circumstances, the particular organization may be exposed to anincreased risk that the data may be accessed by a third party (e.g.,cybercrime) or that the particular organization may not be in compliancewith one or more legal or industry requirements related to thecollection, storage, and/or processing of this orphaned data.

Additionally, in some implementations, in response to the termination ofa particular privacy campaign, processing activity, (e.g., manually orautomatically), the system may be configured to analyze the data modelto determine whether any of the personal data that has been collectedand stored by the particular organization is now orphaned data (e.g.,whether any personal data collected and stored as part of thenow-terminated privacy campaign is being utilized by any otherprocessing activity, has some other legal basis for its continuedstorage, etc.).

In additional implementations in response to determining that aparticular privacy campaign, processing activity, etc. has not beenutilized for a period of time (e.g., a day, month, year), the system maybe configured to terminate the particular privacy campaign, processingactivity, etc. or prompt one or more individuals associated with theparticular organization to indicate whether the particular privacycampaign, processing activity, etc. should be terminated or otherwisediscontinued.

For example, a particular processing activity may include transmissionof a periodic advertising e-mail for a particular company (e.g., ahardware store). As part of the processing activity, the particularcompany may have collected and stored e-mail addresses for customersthat elected to receive (e.g., consented to the receipt of) promotionale-mails. In response to determining that the particular company has notsent out any promotional e-mails for at least a particular amount oftime (e.g., for at least a particular number of months), the system maybe configured to: (1) automatically terminate the processing activity;(2) identify any of the personal data collected as part of theprocessing activity that is now orphaned data (e.g., the e-mailaddresses); and (3) automatically delete the identified orphaned data.The processing activity may have ended for any suitable reason (e.g.,because the promotion that drove the periodic e-mails has ended). As maybe understood in light of this disclosure, because the particularorganization no longer has a valid basis for continuing to store thee-mail addresses of the customers once the e-mail addresses are nolonger being used to send promotional e-mails, the organization may wishto substantially automate the removal of personal data stored in itscomputer systems that may place the organization in violation of one ormore personal data storage rules or regulations.

When the particular privacy campaign, processing activity, etc. isterminated or otherwise discontinued, the system may use the data modelto determine if any of the associated personal data that has beencollected and stored by the particular organization is now orphaneddata.

In various embodiments, the system may be configured to identifyorphaned data of a particular organization and automatically delete thedata. In some implementations, in response to identifying the orphaneddata, the system may present the data to one or more individualsassociated with the particular organization (e.g., a privacy officer)and prompt the one or more individuals to indicate why the orphaned datais being stored by the particular organization. The system may thenenable the individual to provide one or more valid reasons for thedata's continued storage, or enable the one or more individuals todelete the particular orphaned data. In some embodiments, the system mayautomatically delete the orphaned data if, for example: (1) in responseto determining that a reason provided by the individual is not asufficient basis for the continued storage of the personal data; (2) theindividual does not respond to the request to provide one or more validreasons in a timely manner; (3) etc. In some embodiments, one or moreother individuals may review the response provided indicating why theorphaned data is being stored, and in some embodiments, the one or moreother individuals can delete the particular orphaned data.

In various embodiments, the system may be configured to review the datacollection policy (e.g., how data is acquired, security of data storage,who can access the data, etc.) for the particular organization as wellas one or more data retention metrics for the organization. For example,the one or more data retention metrics may include how much personaldata is being collected, how long the data is held, how many privacycampaigns or other processes are using the personal data, etc.Additionally, the system may compare the particular organization's datacollection policy and data retention metrics to the industry standards(e.g., in a particular field, based on a company size, etc.). In variousembodiments, the system may be configured to generate a report thatincludes the comparison and provide the report to the particularorganization (e.g., in electronic format).

In particular embodiments, the system may be configured advise theparticular organization to delete data and identify particular data thatshould be deleted. In some embodiments, the system may automaticallydelete particular data (e.g., orphaned data). Further, the system may beconfigured to calculate and provide a risk score for particular data orthe organization's data collection policy overall. In particularembodiments, the system may be configured to calculate the risk scorebased on the combinations of personal data elements in the datainventory of the organization (e.g., where an individual's phone numberis stored in one location and their mailing address is stored in anotherlocation), and as such the risk may be increased because the additionalpieces of personal information can make the stored data more sensitive.

In particular embodiments, any entity (e.g., organization, company,etc.) that collects, stores, processes, etc. personal data may requireone or more of: (1) consent from a data subject from whom the personaldata is collected and/or processed; and/or (2) a lawful basis for thecollection and/or processing of the personal data. In variousembodiments, the entity may be required to, for example, demonstratethat a data subject has freely given specific, informed, and unambiguousindication of the data subject's agreement to the processing of his orher personal data for one or more specific purposes (e.g., in the formof a statement or clear affirmative action). As such, in particularembodiments, an organization may be required to demonstrate a lawfulbasis for each piece of personal data that the organization hascollected, processed, and/or stored. In particular, each piece ofpersonal data that an organization or entity has a lawful basis tocollect and process may be tied to a particular processing activityundertaken by the organization or entity.

A particular organization may undertake a plurality of different privacycampaigns, processing activities, etc. that involve the collection andstorage of personal data. In some embodiments, each of the plurality ofdifferent processing activities may collect redundant data (e.g., maycollect the same personal data for a particular individual more thanonce), and may store data and/or redundant data in one or moreparticular locations (e.g., on one or more different servers, in one ormore different databases, etc.). In this way, because of the number ofprocessing activities that an organization may undertake, and the amountof data collected as part of those processing activities over time, oneor more data systems associated with an entity or organization may storeor continue to store data that is not associated with any particularprocessing activity (e.g., any particular current processing activity).Under various legal and industry standards related to the collection andstorage of personal data, such data may not have or may no longer have alegal basis for the organization or entity to continue to store thedata. As such, organizations and entities may require improved systemsand methods to maintain an inventory of data assets utilized to processand/or store personal data for which a data subject has provided consentfor such storage and/or processing.

In various embodiments, the system is configured to provide athird-party data repository system to facilitate the receipt andcentralized storage of personal data for each of a plurality ofrespective data subjects, as described herein. Additionally, thethird-party data repository system is configured to interface with acentralized consent receipt management system.

In particular embodiments, the system may be configured to use one ormore website scanning tools to, for example, identify a form (e.g., awebform) and locate a data asset where the input data is transmitted(e.g., Salesforce). Additionally, the system may be configured to addthe data asset to the third-party data repository (e.g., and/or datamap/data inventory) with a link to the form. In response to a userinputting form data (e.g., name, address, credit card information, etc.)of the form and submitting the form, the system may, based on the linkto the form, create a unique subject identifier to submit to thethird-party data repository and, along with the form data, to the dataasset. Further, the system may use the unique subject identifier of auser to access and update each of the data assets of the particularorganization. For example, in response to a user submitting a datasubject access request to delete the user's personal data that theparticular organization has stored, the system may use the uniquesubject identifier of the user to access and delete the user's personaldata stored in all of the data assets (e.g., Salesforce, Eloqua,Marketo, etc.) utilized by the particular organization.

The system may, for example: (1) generate, for each of a plurality ofdata subjects, a respective unique subject identifier in response tosubmission, by each data subject, of a particular form; (2) maintain adatabase of each respective unique subject identifier; and (3)electronically link each respective unique subject identifier to eachof: (A) a form initially submitted by the user; and (B) one or more dataassets that utilize data received from the data subject via the form.

In various embodiments, the system may be configured to, for example:(1) identify a form used to collect one or more pieces of personal data,(2) determine a data asset of a plurality of data assets of theorganization where input data of the form is transmitted, (3) add thedata asset to the third-party data repository with an electronic link tothe form, (4) in response to a user submitting the form, create a uniquesubject identifier to submit to the third-party data repository and,along with the form data provided by the user in the form, to the dataasset, (5) submit the unique subject identifier and the form dataprovided by the user in the form to the third-party data repository andthe data asset, and (6) digitally store the unique subject identifierand the form data provided by the user in the form in the third-partydata repository and the data asset.

In some embodiments, the system may be further configured to, forexample: (1) receive a data subject access request from the user (e.g.,a data subject rights' request, a data subject deletion request, etc.),(2) access the third-party data repository to identify the uniquesubject identifier of the user, (3) determine which data assets of theplurality of data assets of the organization include the unique subjectidentifier, (4) access personal data of the user stored in each of thedata assets of the plurality of data assets of the organization thatinclude the unique subject identifier, and (5) take one or more actionsbased on the data subject access request (e.g., delete the accessedpersonal data in response to a data subject deletion request).

Various privacy and security policies (e.g., such as the EuropeanUnion's General Data Protection Regulation, and other such policies) mayprovide data subjects (e.g., individuals, organizations, or otherentities) with certain rights related to the data subject's personaldata that is collected, stored, or otherwise processed by an entity. Inparticular, under various privacy and security policies, a data subjectmay be entitled to a right to erasure of any personal data associatedwith that data subject that has been at least temporarily stored by theentity (e.g., a right to be forgotten). In various embodiments, underthe right to erasure, an entity (e.g., a data controller on behalf ofanother organization) may be obligated to erase personal data withoutundue delay under one or more of the following conditions: (1) thepersonal data is no longer necessary in relation to a purpose for whichthe data was originally collected or otherwise processed; (2) the datasubject has withdrawn consent on which the processing of the personaldata is based (e.g., and there is no other legal grounds for suchprocessing); (3) the personal data has been unlawfully processed; (4)the data subject has objected to the processing and there is nooverriding legitimate grounds for the processing of the data by theentity; and/or (5) for any other suitable reason or under any othersuitable conditions.

In particular embodiments, a personal data deletion system may beconfigured to: (1) at least partially automatically identify and deletepersonal data that an entity is required to erase under one or more ofthe conditions discussed above; and (2) perform one or more data testsafter the deletion to confirm that the system has, in fact, deleted anypersonal data associated with the data subject.

In particular embodiments, in response to a data subject submitting arequest to delete their personal data from an entity's systems, thesystem may, for example: (1) automatically determine where the datasubject's personal data is stored; and (2) in response to determiningthe location of the data (which may be on multiple computing systems),automatically facilitate the deletion of the data subject's personaldata from the various systems (e.g., by automatically assigning aplurality of tasks to delete data across multiple business systems toeffectively delete the data subject's personal data from the systems).In particular embodiments, the step of facilitating the deletion maycomprise, for example: (1) overwriting the data in memory; (2) markingthe data for overwrite; (2) marking the data as free (e.g., deleting adirectory entry associated with the data); and/or (3) using any othersuitable technique for deleting the personal data. In particularembodiments, as part of this process, the system may use any suitabledata modelling technique to efficiently determine where all of the datasubject's personal data is stored.

In various embodiments, the system may be configured to store (e.g., inmemory) an indication that the data subject has requested to delete anyof their personal data stored by the entity has been processed. Undervarious legal and industry policies/standards, the entity may have acertain period of time (e.g., a number of days) in order to comply withthe one or more requirements related to the deletion or removal ofpersonal data in response to receiving a request from the data subjector in response to identifying one or more of the conditions requiringdeletion discussed above. In response to the receiving of an indicationthat the deletion request for the data subject's personal data has beenprocessed or the certain period of time (described above) has passed,the system may be configured to perform a data test to confirm thedeletion of the data subject's personal data.

In particular embodiments, when performing the data test, the system maybe configured to provide an interaction request to the entity on behalfof the data subject. In particular embodiments, the interaction requestmay include, for example, a request for one or more pieces of dataassociated with the data subject (e.g., account information, etc.). Invarious embodiments, the interaction request is a request to contact thedata subject (e.g., for any suitable reason). The system may, forexample, be configured to substantially automatically complete acontact-request form (e.g., a webform made available by the entity) onbehalf of the data subject. In various embodiments, when automaticallycompleting the form on behalf of the data subject, the system may beconfigured to only provide identifying data, but not provide any contactdata. In response to submitting the interaction request (e.g.,submitting the webform), the system may be configured to determinewhether the one or more computers systems have generated and/ortransmitted a response to the data subject. The system may be configuredto determine whether the one or more computers systems have generatedand/or transmitted the response to the data subject by, for example,analyzing one or more computer systems associated with the entity todetermine whether the one or more computer systems have generated acommunication to the data subject (e.g., automatically) for transmissionto an e-mail address or other contact method associated with the datasubject, generated an action-item for an individual to contact the datasubject at a particular contact number, etc.

In response to determining that the one or more computer systems hasgenerated and/or transmitted the response to the data subject, thesystem may be configured to determine that the one or more computersystems has not complied with the data subject's request for deletion oftheir personal data from the one or more computers systems associatedwith the entity. In response, the system may generate an indication thatthe one or more computer systems has not complied with the datasubject's request for deletion of their personal data from the one ormore computers systems have, and store the indication in computermemory.

To perform the data test, for example, the system may be configured to:(1) access (e.g., manually or automatically) a form for the entity(e.g., a web-based “Contact Us” form); (2) input a unique identifierassociated with the data subject (e.g., a full name or customer IDnumber) without providing contact information for the data subject(e.g., mailing address, phone number, email address, etc.); and (3)input a request, within the form, for the entity to contact the datasubject to provide information associated with the data subject (e.g.,the data subject's account balance with the entity). In response tosubmitting the form to the entity, the system may be configured todetermine whether the data subject is contacted (e.g., via a phone callor email) by the one or more computer systems (e.g., automatically). Inresponse to determining that the data subject has been contactedfollowing submission of the form, the system may determine that the oneor more computer systems have not fully deleted the data subject'spersonal data (e.g., because the one or more computer systems must stillbe storing contact information for the data subject in at least onelocation).

In particular embodiments, the system is configured to generate one ormore test profiles for one or more test data subjects. For each of theone or more test data subjects, the system may be configured to generateand store test profile data such as, for example: (1) name; (2) address;(3) telephone number; (4) e-mail address; (5) social security number;(6) information associated with one or more credit accounts (e.g.,credit card numbers); (7) banking information; (8) location data; (9)internet search history; (10) non-credit account data; and/or (11) anyother suitable test data. The system may then be configured to at leastinitially consent to processing or collection of personal data for theone or more test data subjects by the entity. The system may thenrequest deletion, by the entity, of any personal data associated with aparticular test data subject. In response to requesting the deletion ofdata for the particular test data subject, the system may then take oneor more actions using the test profile data associated with theparticular test data subjects in order to confirm that the one or morecomputers systems have, in fact, deleted the test data subject'spersonal data (e.g., any suitable action described herein). The systemmay, for example, be configured to: (1) initiate a contact request onbehalf of the test data subject; (2) attempt to login to one or moreuser accounts that the system had created for the particular test datasubject; and/or (3) take any other action, the effect of which couldindicate a lack of complete deletion of the test data subject's personaldata.

In response to determining that the one or more computer systems havenot fully deleted a data subject's (or test data subject's) personaldata, the system may then be configured, in particular embodiments, to:(1) flag the data subject's personal data for follow up by one or moreprivacy officers to investigate the lack of deletion; (2) perform one ormore scans of one or more computing systems associated with the entityto identify any residual personal data that may be associated with thedata subject; (3) generate a report indicating the lack of completedeletion; and/or (4) take any other suitable action to flag forfollow-up the data subject, personal data, initial request to beforgotten, etc.

The system may, for example, be configured to test to ensure the datahas been deleted by: (1) submitting a unique token of data through aform to a system (e.g., mark to); (2) in response to passage of anexpected data retention time, test the system by calling into the systemafter the passage of the data retention time to search for the uniquetoken. In response to finding the unique token, the system may beconfigured to determine that the data has not been properly deleted.

In various embodiments, a system may be configured to substantiallyautomatically determine whether to take one or more actions in responseto one or more identified risk triggers. For example, an identified risktrigger may be that a data asset for an organization is hosted in onlyone particular location thereby increasing the scope of risk if thelocation were infiltrated (e.g., via cybercrime). In particularembodiments, the system is configured to substantially automaticallyperform one or more steps related to the analysis of and response to theone or more potential risk triggers discussed above. For example, thesystem may substantially automatically determine a relevance of a riskposed by (e.g., a risk level) the one or more potential risk triggersbased at least in part on one or more previously-determined responses tosimilar risk triggers. This may include, for example, one or morepreviously determined responses for the particular entity that hasidentified the current risk trigger, one or more similarly situatedentities, or any other suitable entity or potential trigger.

In particular embodiments, the system may, for example, be configuredto: (1) receive risk remediation data for a plurality of identified risktriggers from a plurality of different entities; (2) analyze the riskremediation data to determine a pattern in assigned risk levels anddetermined response to particular risk triggers; and (3) develop a modelbased on the risk remediation data for use in facilitating an automaticassessment of and/or response to future identified risk triggers.

In some embodiments, when a change or update is made to one or moreprocessing activities and/or data assets (e.g., a database associatedwith a particular organization), the system may use data modelingtechniques to update the risk remediation data for use in facilitatingan automatic assessment of and/or response to future identified risktriggers. In various embodiments, when a privacy campaign, processingactivity, etc. of the particular organization is modified (e.g., add,remove, or update particular information), then the system may use therisk remediation data for use in facilitating an automatic assessment ofand/or response to future identified risk triggers.

In particular embodiments, the system may, for example, be configuredto: (1) access risk remediation data for an entity that identifies oneor more suitable actions to remediate a risk in response to identifyingone or more data assets of the entity that may be affected by one ormore potential risk triggers; (2) receive an indication of an update tothe one or more data assets; (3) identify one or more potential updatedrisk triggers for an entity; (4) assess and analyze the one or morepotential updated risk triggers to determine a relevance of a risk posedto the entity by the one or more potential updated risk triggers; (5)use one or more data modeling techniques to identify one or more dataassets associated with the entity that may be affected by the risk; and(6) update the risk remediation data to include the one or more actionsto remediate the risk in response to identifying the one or morepotential updated risk triggers.

In any embodiment described herein, an automated classification systemmay be configured to substantially automatically classify one or morepieces of personal information in one or more documents (e.g., one ormore text-based documents, one or more spreadsheets, one or more PDFs,one or more webpages, etc.). In particular embodiments, the system maybe implemented in the context of any suitable privacy compliance system,which may, for example, be configured to calculate and assign asensitivity score to a particular document based at least in part on oneor more determined categories of personal information (e.g., personaldata) identified in the one or more documents. As understood in the art,the storage of particular types of personal information may be governedby one or more government or industry regulations. As such, it may bedesirable to implement one or more automated measures to automaticallyclassify personal information from stored documents (e.g., to determinewhether such documents may require particular security measures, storagetechniques, handling, whether the documents should be destroyed, etc.).

Technical Contributions of Various Embodiments

An entity that handles (e.g., collects, receives, transmits, stores,processes, shares, and/or the like) sensitive and/or personalinformation associated with particular individuals (e.g., personallyidentifiable information (PII) data, sensitive data, personal data,etc.) may obtain consent from such individuals to process their personalinformation and may receive data access requests from such individualsto provide information about how the entity handles personal data (e.g.,a data subject rights request, data subject access request (DSAR),etc.). Because an entity may handle personal data for many individuals(e.g., data subjects) and may have such personal data stored across manydifferent systems, it can be challenging to efficiently track and locatesuch data when requested to do quickly and efficiently. Moreover, anentity may receive such data via webforms associated with many differentwebsites and webpages, each of which may be associated with varying dataassets used to store and process data received through such webforms.Consent data for the use of the personal data submitted via suchwebforms may also be received by the system and stored across manydifferent data assets. These and other factors related to operating acomplex system of interconnected (e.g., networked) computing devicesthat interact with a vast number of data subjects and handle associateddata increase the challenges associated with quickly and efficientlylocating and retrieving personal data in response to a data accessrequest.

Accordingly, various embodiments of the present disclosure overcome manyof the technical challenges associated with efficiently retrievingpersonal data for large numbers of data subjects and processing largequantities of requests for such data in a networked computingenvironment that involves constantly changing consent preferences anddata stored for each such data subject. More particularly, variousembodiments of the present disclosure include applying one or moreparticular sets of results or methods in receiving data from a datasubject via a webform and tracking such data and the data subject forefficient determination of such data in response to a future request forsuch data. The various embodiments of the disclosure are directed to acomputational framework configured for analyzing a webform to determinethe data asset that will receive data submitted via the webform andgenerating an electronic association or link at a consent repositoryassociating the webform and the data asset. In response to a submissionof the webform by a particular data subject, the assigns a uniqueidentifier to the data subject (generating the unique identifier ifnecessary) and associates the data submitted by the data subject via thewebform with the identifier in the consent repository. The system alsoassociates the data submitted by the data subject via the webform withthe identifier in the data asset. In response to a request from theparticular data subject for the data subject's personal data, the systemuses the data subject's unique identifier, the mapping in the consentrepository of the unique identifier to the form data (e.g., identifyingthe webform), and the mapping in the consent repository of the webformto the data asset to identify the data asset that stores the datasubject's personal data. The system can then efficiently identify andretrieve the personal data using a centralized system mapping the datasubject, the webforms submitted by the data subject, and the data assetson which the data subject's personal data may be processed or storedwhen submitted via such webforms. The disclosed embodiments improve theperformance of processing a data access request, enabling faster andmore accurate data recall using the mappings of unique identifiers toassets where personal data is stored via webform data in a consentrepository.

Accordingly, various embodiments of the disclosure provided herein aremore effective, efficient, accurate, and faster in identifying andretrieving personal data and related information for a particular datasubject regardless of the webform through which such data was receivedor the data asset on which such data may be stored. The variousembodiments also provide improved means of obtaining consent preferencesassociated with such data. This is especially advantageous when anentity receives many requests for personal data and related informationfrom many different data subject, where the requested data may have beenreceived across many websites and webpages that each may use variouswebforms. In facilitating the efficient identification and retrieval ofpersonal data and related information, the various embodiments of thepresent disclosure make major technical contributions to improving thecomputational efficiency and reliability of various privacy managementsystems and procedures for processing requests for data access. This inturn translates to more computationally efficient software systems.

Exemplary Technical Platforms

As will be appreciated by one skilled in the relevant field, the presentinvention may be, for example, embodied as a computer system, a method,or a computer program product. Accordingly, various embodiments may takethe form of an entirely hardware embodiment, an entirely softwareembodiment, or an embodiment combining software and hardware aspects.Furthermore, particular embodiments may take the form of a computerprogram product stored on a computer-readable storage medium havingcomputer-readable instructions (e.g., software) embodied in the storagemedium. Various embodiments may take the form of web-implementedcomputer software. Any suitable computer-readable storage medium may beutilized including, for example, hard disks, compact disks, DVDs,optical storage devices, and/or magnetic storage devices.

Various embodiments are described below with reference to block diagramsand flowchart illustrations of methods, apparatuses (e.g., systems), andcomputer program products. It should be understood that each block ofthe block diagrams and flowchart illustrations, and combinations ofblocks in the block diagrams and flowchart illustrations, respectively,can be implemented by a computer executing computer programinstructions. These computer program instructions may be loaded onto ageneral purpose computer, special purpose computer, or otherprogrammable data processing apparatus to produce a machine, such thatthe instructions which execute on the computer or other programmabledata processing apparatus to create means for implementing the functionsspecified in the flowchart block or blocks.

These computer program instructions may also be stored in acomputer-readable memory that can direct a computer or otherprogrammable data processing apparatus to function in a particularmanner such that the instructions stored in the computer-readable memoryproduce an article of manufacture that is configured for implementingthe function specified in the flowchart block or blocks. The computerprogram instructions may also be loaded onto a computer or otherprogrammable data processing apparatus to cause a series of operationalsteps to be performed on the computer or other programmable apparatus toproduce a computer implemented process such that the instructions thatexecute on the computer or other programmable apparatus provide stepsfor implementing the functions specified in the flowchart block orblocks.

Accordingly, blocks of the block diagrams and flowchart illustrationssupport combinations of mechanisms for performing the specifiedfunctions, combinations of steps for performing the specified functions,and program instructions for performing the specified functions. Itshould also be understood that each block of the block diagrams andflowchart illustrations, and combinations of blocks in the blockdiagrams and flowchart illustrations, can be implemented by specialpurpose hardware-based computer systems that perform the specifiedfunctions or steps, or combinations of special purpose hardware andother hardware executing appropriate computer instructions.

Example System Architecture

FIG. 1 is a block diagram of a Data Model Generation and PopulationSystem 100 according to a particular embodiment. In various embodiments,the Data Model Generation and Population System 100 is part of a privacycompliance system (also referred to as a privacy management system), orother system, which may, for example, be associated with a particularorganization and be configured to aid in compliance with one or morelegal or industry regulations related to the collection and storage ofpersonal data. In some embodiments, the Data Model Generation andPopulation System 100 is configured to: (1) generate a data model basedon one or more identified data assets, where the data model includes adata inventory associated with each of the one or more identified dataassets; (2) identify populated and unpopulated aspects of each datainventory; and (3) populate the unpopulated aspects of each datainventory using one or more techniques such as intelligent identityscanning, questionnaire response mapping, APIs, etc.

As may be understood from FIG. 1 , the Data Model Generation andPopulation System 100 includes one or more computer networks 115, a DataModel Generation Server 110, a Data Model Population Server 120, anIntelligent Identity Scanning Server 130, One or More Databases 140 orother data structures, one or more remote computing devices 150 (e.g., adesktop computer, laptop computer, tablet computer, smartphone, etc.),and One or More Third Party Servers 160. In particular embodiments, theone or more computer networks 115 facilitate communication between theData Model Generation Server 110, Data Model Population Server 120,Intelligent Identity Scanning Server 130, One or More Databases 140, oneor more remote computing devices 150 (e.g., a desktop computer, laptopcomputer, tablet computer, smartphone, etc.), and One or More ThirdParty Servers 160. Although in the embodiment shown in FIG. 1 , the DataModel Generation Server 110, Data Model Population Server 120,Intelligent Identity Scanning Server 130, One or More Databases 140, oneor more remote computing devices 150 (e.g., a desktop computer, laptopcomputer, tablet computer, smartphone, etc.), and One or More ThirdParty Servers 160 are shown as separate servers, it should be understoodthat in other embodiments, one or more of these servers and/or computingdevices may comprise a single server, a plurality of servers, one ormore cloud-based servers, or any other suitable configuration. It shouldbe further understood that although any particular name given to anyparticular server in the course of this description should not beunderstood to imply any limit to any functionality that such a servermay provide to the system. For example, a scanning server may beimplemented along with one or more other servers to generate, automate,execute, and/or fulfill one or more data subject access requests.Similarly, a data model population server may be configured to executeone or more scanning steps described herein, etc.

The one or more computer networks 115 may include any of a variety oftypes of wired or wireless computer networks such as the Internet, aprivate intranet, a public switch telephone network (PSTN), or any othertype of network. The communication link between The Intelligent IdentityScanning Server 130 and the One or More Third Party Servers 160 may be,for example, implemented via a Local Area Network (LAN) or via theInternet. In other embodiments, the One or More Databases 140 may bestored either fully or partially on any suitable server or combinationof servers described herein.

FIG. 2 illustrates a diagrammatic representation of a computer 200 thatcan be used within the Data Model Generation and Population System 100,for example, as a client computer (e.g., one or more remote computingdevices 130 shown in FIG. 1 ), or as a server computer (e.g., Data ModelGeneration Server 110 shown in FIG. 1 ). In particular embodiments, thecomputer 200 may be suitable for use as a computer within the context ofthe Data Model Generation and Population System 100 that is configuredto generate a data model and map one or more relationships between oneor more pieces of data that make up the model.

In particular embodiments, the computer 200 may be connected (e.g.,networked) to other computers in a LAN, an intranet, an extranet, and/orthe Internet. As noted above, the computer 200 may operate in thecapacity of a server or a client computer in a client-server networkenvironment, or as a peer computer in a peer-to-peer (or distributed)network environment. The Computer 200 may be a personal computer (PC), atablet PC, a set-top box (STB), a Personal Digital Assistant (PDA), acellular telephone, a web appliance, a server, a network router, aswitch or bridge, or any other computer capable of executing a set ofinstructions (sequential or otherwise) that specify actions to be takenby that computer. Further, while only a single computer is illustrated,the term “computer” shall also be taken to include any collection ofcomputers that individually or jointly execute a set (or multiple sets)of instructions to perform any one or more of the methodologiesdiscussed herein.

An exemplary computer 200 includes a processing device 202, a mainmemory 204 (e.g., read-only memory (ROM), flash memory, dynamic randomaccess memory (DRAM) such as synchronous DRAM (SDRAM) or Rambus DRAM(RDRAM), etc.), static memory 206 (e.g., flash memory, static randomaccess memory (SRAM), etc.), and a data storage device 218, whichcommunicate with each other via a bus 232.

The processing device 202 represents one or more general-purposeprocessing devices such as a microprocessor, a central processing unit,or the like. More particularly, the processing device 202 may be acomplex instruction set computing (CISC) microprocessor, reducedinstruction set computing (RISC) microprocessor, very long instructionword (VLIW) microprocessor, or processor implementing other instructionsets, or processors implementing a combination of instruction sets. Theprocessing device 202 may also be one or more special-purpose processingdevices such as an application specific integrated circuit (ASIC), afield programmable gate array (FPGA), a digital signal processor (DSP),network processor, or the like. The processing device 202 may beconfigured to execute processing logic 226 for performing variousoperations and steps discussed herein.

The computer 120 may further include a network interface device 208. Thecomputer 200 also may include a video display unit 210 (e.g., a liquidcrystal display (LCD) or a cathode ray tube (CRT)), an alphanumericinput device 212 (e.g., a keyboard), a cursor control device 214 (e.g.,a mouse), and a signal generation device 216 (e.g., a speaker).

The data storage device 218 may include a non-transitorycomputer-accessible storage medium 230 (also known as a non-transitorycomputer-readable storage medium or a non-transitory computer-readablemedium) on which is stored one or more sets of instructions (e.g.,software instructions 222) embodying any one or more of themethodologies or functions described herein. The software instructions222 may also reside, completely or at least partially, within mainmemory 204 and/or within processing device 202 during execution thereofby computer 200—main memory 204 and processing device 202 alsoconstituting computer-accessible storage media. The softwareinstructions 222 may further be transmitted or received over a network115 via network interface device 208.

While the computer-accessible storage medium 230 is shown in anexemplary embodiment to be a single medium, the term“computer-accessible storage medium” should be understood to include asingle medium or multiple media (e.g., a centralized or distributeddatabase, and/or associated caches and servers) that store the one ormore sets of instructions. The term “computer-accessible storage medium”should also be understood to include any medium that is capable ofstoring, encoding or carrying a set of instructions for execution by thecomputer and that cause the computer to perform any one or more of themethodologies of the present invention. The term “computer-accessiblestorage medium” should accordingly be understood to include, but not belimited to, solid-state memories, optical and magnetic media, etc.

Exemplary System Platform

Various embodiments of a Data Model Generation and Population System 100may be implemented in the context of any suitable system (e.g., aprivacy compliance system). For example, the Data Model Generation andPopulation System 100 may be implemented to analyze a particular companyor other organization's data assets to generate a data model for one ormore processing activities, privacy campaigns, etc. undertaken by theorganization. In particular embodiments, the system may implement one ormore modules in order to at least partially ensure compliance with oneor more regulations (e.g., legal requirements) related to the collectionand/or storage of personal data. Various aspects of the system'sfunctionality may be executed by certain system modules, including aData Model Generation Module 300, Data Model Population Module 1100,Data Population Questionnaire Generation Module 1200, IntelligentIdentity Scanning Module 2600, Data Subject Access Request FulfillmentModule 2900, Cross-Border Visualization Generation Module 3600, AdaptiveExecution on a Data Model Module 3900, E-mail Scanning Module 4100,Webform Crawling Module 4300, and Data Asset and Webform ManagementModule 4400. These modules are discussed in greater detail below.

Although these modules are presented as a series of steps, it should beunderstood in light of this disclosure that various embodiments of theData Model Generation Module 300, Data Model Population Module 1100,Data Population Questionnaire Generation Module 1200, IntelligentIdentity Scanning Module 2600, Data Subject Access Request FulfillmentModule 2900, Cross-Border Visualization Generation Module 3600, AdaptiveExecution on a Data Model Module 3900, E-mail Scanning Module 4100,Webform Crawling Module 4300, and Data Asset and Webform ManagementModule 4400 described herein may perform the steps described below in anorder other than in which they are presented. In still otherembodiments, the Data Model Generation Module 300, Data Model PopulationModule 1100, Data Population Questionnaire Generation Module 1200,Intelligent Identity Scanning Module 2600, Data Subject Access RequestFulfillment Module 2900, Cross-Border Visualization Generation Module3600, Adaptive Execution on a Data Model Module 3900, E-mail ScanningModule 4100, Webform Crawling Module 4300, and Data Asset and WebformManagement Module 4400 may omit certain steps described below. Invarious other embodiments, the Data Model Generation Module 300, DataModel Population Module 1100, Data Population Questionnaire GenerationModule 1200, Intelligent Identity Scanning Module 2600, Data SubjectAccess Request Fulfillment Module 2900, Cross-Border VisualizationGeneration Module 3600, Adaptive Execution on a Data Model Module 3900,E-mail Scanning Module 4100, Webform Crawling Module 4300, and DataAsset and Webform Management Module 4400 may perform steps in additionto those described (e.g., such as one or more steps described withrespect to one or more other modules, etc.).

In particular embodiments, the steps that the system executes whenexecuting any of the modules described herein may be performed by anysuitable computer server or combination of computer servers (e.g., anysuitable computing device, server, or combination of computing deviceand/or server described herein).

Data Model Generation Module

In particular embodiments, a Data Model Generation Module 300 isconfigured to: (1) generate a data model (e.g., a data inventory) forone or more data assets utilized by a particular organization; (2)generate a respective data inventory for each of the one or more dataassets; and (3) map one or more relationships between one or moreaspects of the data inventory, the one or more data assets, etc. withinthe data model. In particular embodiments, a data asset (e.g., datasystem, software application, etc.) may include, for example, any entitythat collects, processes, contains, and/or transfers data (e.g., such asa software application, “internet of things” computerized device,database, website, data-center, server, etc.). For example, a first dataasset may include any software or device (e.g., server or servers)utilized by a particular entity for such data collection, processing,transfer, storage, etc.

In particular embodiments, a particular data asset, or collection ofdata assets, may be utilized as part of a particular data processingactivity (e.g., direct deposit generation for payroll purposes). Invarious embodiments, a data model generation system may, on behalf of aparticular organization (e.g., entity), generate a data model thatencompasses a plurality of processing activities. In other embodiments,the system may be configured to generate a discrete data model for eachof a plurality of processing activities undertaken by an organization.

Turning to FIG. 3 , in particular embodiments, when executing the DataModel Generation Module 300, the system begins, at Step 310, bygenerating a data model for one or more data assets and digitallystoring the data model in computer memory. The system may, for example,store the data model in the One or More Databases 140 described above(or any other suitable data structure). In various embodiments,generating the data model comprises generating a data structure thatcomprises information regarding one or more data assets, attributes andother elements that make up the data model. As may be understood inlight of this disclosure, the one or more data assets may include anydata assets that may be related to one another. In particularembodiments, the one or more data assets may be related by virtue ofbeing associated with a particular entity (e.g., organization). Forexample, the one or more data assets may include one or more computerservers owned, operated, or utilized by the entity that at leasttemporarily store data sent, received, or otherwise processed by theparticular entity.

In still other embodiments, the one or more data assets may comprise oneor more third party assets which may, for example, send, receive and/orprocess personal data on behalf of the particular entity. These one ormore data assets may include, for example, one or more softwareapplications (e.g., such as Expensify to collect expense information,QuickBooks to maintain and store salary information, etc.).

Continuing to step 320, the system is configured to identify a firstdata asset of the one or more data assets. In particular embodiments,the first data asset may include, for example, any entity (e.g., system)that collects, processes, contains, and/or transfers data (e.g., such asa software application, “internet of things” computerized device,database, website, data-center, server, etc.). For example, the firstdata asset may include any software or device utilized by a particularorganization for such data collection, processing, transfer, etc. Invarious embodiments, the first data asset may be associated with aparticular processing activity (e.g., the first data asset may make upat least a part of a data flow that relates to the collection, storage,transfer, access, use, etc. of a particular piece of data (e.g.,personal data)). Information regarding the first data asset may clarify,for example, one or more relationships between and/or among one or moreother data assets within a particular organization. In a particularexample, the first data asset may include a software applicationprovided by a third party (e.g., a third party vendor) with which theparticular entity interfaces for the purpose of collecting, storing, orotherwise processing personal data (e.g., personal data regardingcustomers, employees, potential customers, etc.).

In particular embodiments, the first data asset is a storage asset thatmay, for example: (1) receive one or more pieces of personal data formone or more collection assets; (2) transfer one or more pieces ofpersonal data to one or more transfer assets; and/or (3) provide accessto one or more pieces of personal data to one or more authorizedindividuals (e.g., one or more employees, managers, or other authorizedindividuals within a particular entity or organization). In a particularembodiment, the first data asset is a primary data asset associated witha particular processing activity around which the system is configuredto build a data model associated with the particular processingactivity.

In particular embodiments, the system is configured to identify thefirst data asset by scanning a plurality of computer systems associatedwith a particular entity (e.g., owned, operated, utilized, etc. by theparticular entity). In various embodiments, the system is configured toidentify the first data asset from a plurality of data assets identifiedin response to completion, by one or more users, of one or morequestionnaires.

Advancing to Step 330, the system generates a first data inventory ofthe first data asset. The data inventory may comprise, for example, oneor more inventory attributes associated with the first data asset suchas, for example: (1) one or more processing activities associated withthe first data asset; (2) transfer data associated with the first dataasset (e.g., how and where the data is being transferred to and/orfrom); (3) personal data associated with the first data asset (e.g.,what type of personal data is collected and/or stored by the first dataasset; how, and from where, the data is collected, etc.); (4) storagedata associated with the personal data (e.g., whether the data is beingstored, protected and deleted); and (5) any other suitable attributerelated to the collection, use, and transfer of personal data. In otherembodiments, the one or more inventory attributes may comprise one ormore other pieces of information such as, for example: (1) the type ofdata being stored by the first data asset; (2) an amount of data storedby the first data asset; (3) whether the data is encrypted; (4) alocation of the stored data (e.g., a physical location of one or morecomputer servers on which the data is stored); etc. In particular otherembodiments, the one or more inventory attributes may comprise one ormore pieces of information technology data related to the first dataasset (e.g., such as one or more pieces of network and/or infrastructureinformation, IP address, MAC address, etc.).

In various embodiments, the system may generate the data inventory basedat least in part on the type of first data asset. For example,particular types of data assets may have particular default inventoryattributes. In such embodiments, the system is configured to generatethe data inventory for the first data asset, which may, for example,include one or more placeholder fields to be populated by the system ata later time. In this way, the system may, for example, identifyparticular inventory attributes for a particular data asset for whichinformation and/or population of data is required as the system buildsthe data model.

As may be understood in light of this disclosure, the system may, whengenerating the data inventory for the first data asset, generate one ormore placeholder fields that may include, for example: (1) theorganization (e.g., entity) that owns and/or uses the first data asset(a primary data asset, which is shown in the center of the data model inFIG. 4 ); (2) one or more departments within the organization that areresponsible for the first data asset; (3) one or more softwareapplications that collect data (e.g., personal data) for storage inand/or use by the first data asset (e.g., or one or more other suitablecollection assets from which the personal data that is collected,processed, stored, etc. by the first data asset is sourced); (4) one ormore particular data subjects (or categories of data subjects) thatinformation is collected from for use by the first data asset; (5) oneor more particular types of data that are collected by each of theparticular applications for storage in and/or use by the first dataasset; (6) one or more individuals (e.g., particular individuals ortypes of individuals) that are permitted to access and/or use the datastored in, or used by, the first data asset; (7) which particular typesof data each of those individuals are allowed to access and use; and (8)one or more data assets (destination assets) that the data istransferred to from the first data asset, and which particular data istransferred to each of those data assets.

As may be understood in light of this disclosure, the system may beconfigured to generate the one or more placeholder fields based at leastin part on, for example: (1) the type of the first data asset; (2) oneor more third party vendors utilized by the particular organization; (3)a number of collection or storage assets typically associated with thetype of the first data asset; and/or (4) any other suitable factorrelated to the first data asset, its one or more inventory attributes,etc. In other embodiments, the system may substantially automaticallygenerate the one or more placeholders based at least in part on ahierarchy and/or organization of the entity for which the data model isbeing built. For example, a particular entity may have a marketingdivision, legal department, human resources department, engineeringdivision, or other suitable combination of departments that make up anoverall organization. Other particular entities may have furthersubdivisions within the organization. When generating the data inventoryfor the first data asset, the system may identify that the first dataasset will have both an associated organization and subdivision withinthe organization to which it is assigned. In this example, the systemmay be configured to store an indication in computer memory that thefirst data asset is associated with an organization and a departmentwithin the organization.

Next, at Step 340, the system modifies the data model to include thefirst data inventory and electronically links the first data inventoryto the first data asset within the data model. In various embodiments,modifying the data model may include configuring the data model to storethe data inventory in computer memory, and to digitally associate thedata inventory with the first data asset in memory.

FIGS. 4 and 5 show a data model according to a particular embodiment. Asshown in these figures, the data model may store the followinginformation for the first data asset: (1) the organization that ownsand/or uses the first data asset; (2) one or more departments within theorganization that are responsible for the first data asset; (3) one ormore applications that collect data (e.g., personal data) for storage inand/or use by the first data asset; (4) one or more particular datasubjects that information is collected from for use by the first dataasset; (5) one or more collection assets from which the first assetreceives data (e.g., personal data); (6) one or more particular types ofdata that are collected by each of the particular applications (e.g.,collection assets) for storage in and/or use by the first data asset;(7) one or more individuals (e.g., particular individuals, types ofindividuals, or other parties) that are permitted to access and/or usethe data stored in or used by the first data asset; (8) which particulartypes of data each of those individuals are allowed to access and use;and (9) one or more data assets (destination assets) the data istransferred to for other use, and which particular data is transferredto each of those data assets. As shown in FIGS. 6 and 7 , the system mayalso optionally store information regarding, for example, which businessprocesses and processing activities utilize the first data asset.

As noted above, in particular embodiments, the data model stores thisinformation for each of a plurality of different data assets and mayinclude one or more links between, for example, a portion of the modelthat provides information for a first particular data asset and a secondportion of the model that provides information for a second particulardata asset.

Advancing to Step 350, the system next identifies a second data assetfrom the one or more data assets. In various embodiments, the seconddata asset may include one of the one or more inventory attributesassociated with the first data asset (e.g., the second data asset mayinclude a collection asset associated with the first data asset, adestination asset or transfer asset associated with the first dataasset, etc.). In various embodiments, as may be understood in light ofthe exemplary data models described below, a second data asset may be aprimary data asset for a second processing activity, while the firstdata asset is the primary data asset for a first processing activity. Insuch embodiments, the second data asset may be a destination asset forthe first data asset as part of the first processing activity. Thesecond data asset may then be associated with one or more seconddestination assets to which the second data asset transfers data. Inthis way, particular data assets that make up the data model may defineone or more connections that the data model is configured to map andstore in memory.

Returning to Step 360, the system is configured to identify one or moreattributes associated with the second data asset, modify the data modelto include the one or more attributes, and map the one or moreattributes of the second data asset within the data model. The systemmay, for example, generate a second data inventory for the second dataasset that comprises any suitable attribute described with respect tothe first data asset above. The system may then modify the data model toinclude the one or more attributes and store the modified data model inmemory. The system may further, in various embodiments, associate thefirst and second data assets in memory as part of the data model. Insuch embodiments, the system may be configured to electronically linkthe first data asset with the second data asset. In various embodiments,such association may indicate a relationship between the first andsecond data assets in the context of the overall data model (e.g.,because the first data asset may serve as a collection asset for thesecond data asset, etc.).

Next, at Step 370, the system may be further configured to generate avisual representation of the data model. In particular embodiments, thevisual representation of the data model comprises a data map. The visualrepresentation may, for example, include the one or more data assets,one or more connections between the one or more data assets, the one ormore inventory attributes, etc.

In particular embodiments, generating the visual representation (e.g.,visual data map) of a particular data model (e.g., data inventory) mayinclude, for example, generating a visual representation that includes:(1) a visual indication of a first data asset (e.g., a storage asset), asecond data asset (e.g., a collection asset), and a third data asset(e.g., a transfer asset); (2) a visual indication of a flow of data(e.g., personal data) from the second data asset to the first data asset(e.g., from the collection asset to the storage asset); (3) a visualindication of a flow of data (e.g., personal data) from the first dataasset to the third data asset (e.g., from the storage asset to thetransfer asset); (4) one or more visual indications of a risk levelassociated with the transfer of personal data; and/or (5) any othersuitable information related to the one or more data assets, thetransfer of data between/among the one or more data assets, access todata stored or collected by the one or more data assets, etc.

In particular embodiments, the visual indication of a particular assetmay comprise a box, symbol, shape, or other suitable visual indicator.In particular embodiments, the visual indication may comprise one ormore labels (e.g., a name of each particular data asset, a type of theasset, etc.). In still other embodiments, the visual indication of aflow of data may comprise one or more arrows. In particular embodiments,the visual representation of the data model may comprise a data flow,flowchart, or other suitable visual representation.

In various embodiments, the system is configured to display (e.g., to auser) the generated visual representation of the data model on asuitable display device.

Exemplary Data Models and Visual Representations of Data Models (e.g.,Data Maps)

FIGS. 4-10 depict exemplary data models according to various embodimentsof the system described herein. FIG. 4 , for example, depicts anexemplary data model that does not include a particular processingactivity (e.g., that is not associated with a particular processingactivity). As may be understood from the data model shown in thisfigure, a particular data asset (e.g., a primary data asset) may beassociated with a particular company (e.g., organization), ororganization within a particular company, sub-organization of aparticular organization, etc. In still other embodiments, the particularasset may be associated with one or more collection assets (e.g., one ormore data subjects from whom personal data is collected for storage bythe particular asset), one or more parties that have access to datastored by the particular asset, one or more transfer assets (e.g., oneor more assets to which data stored by the particular asset may betransferred), etc.

As may be understood from FIG. 4 , a particular data model for aparticular asset may include a plurality of data elements. Whengenerating the data model for the particular asset, a system may beconfigured to substantially automatically identify one or more types ofdata elements for inclusion in the data model, and automaticallygenerate a data model that includes those identified data elements(e.g., even if one or more of those data elements must remainunpopulated because the system may not initially have access to a valuefor the particular data element). In such cases, the system may beconfigured to store a placeholder for a particular data element untilthe system is able to populate the particular data element with accuratedata.

As may be further understood from FIG. 4 , the data model shown in FIG.4 may represent a portion of an overall data model. For example, in theembodiment shown in this figure, the transfer asset depicted may serveas a storage asset for another portion of the data model. In suchembodiments, the transfer asset may be associated with a respective oneor more of the types of data elements described above. In this way, thesystem may generate a data model that may build upon itself to comprisea plurality of layers as the system adds one or more new data assets,attributes, etc.

As may be further understood from FIG. 4 , a particular data model mayindicate one or more parties that have access to and/or use of theprimary asset (e.g., storage asset). In such embodiments, the system maybe configured to enable the one or more parties to access one or morepieces of data (e.g., personal data) stored by the storage asset.

As shown in FIG. 4 , the data model may further comprise one or morecollection assets (e.g., one or more data assets or individuals fromwhich the storage asset receives data such as personal data). In theexemplary data model (e.g., visual data map) shown in this figure, thecollection assets comprise a data subject (e.g., an individual that mayprovide data to the system for storage in the storage asset) and acollection asset (e.g., which may transfer one or more pieces of datathat the collection asset has collected to the storage asset).

FIG. 5 depicts a portion of an exemplary data model that is populatedfor the primary data asset Gusto. Gusto is a software application that,in the example shown in FIG. 5 , may serve as a human resources servicethat contains financial, expense, review, time and attendance,background, and salary information for one or more employees of aparticular organization (e.g., GeneriTech). In the example of FIG. 5 ,the primary asset (e.g., Gusto) may be utilized by the HR (e.g., HumanResources) department of the particular organization (e.g., GeneriTech).Furthermore, the primary asset, Gusto, may collect financial informationfrom one or more data subjects (e.g., employees of the particularorganization), receive expense information transferred from Expensify(e.g., expensing software), and receive time and attendance datatransferred from Kronos (e.g., timekeeping software). In the exampleshown in FIG. 5 , access to the information collected and/or stored byGusto may include, for example: (1) an ability to view and administersalary and background information by HR employees, and (2) an ability toview and administer employee review information by one or more servicemanagers. In the example shown in this figure, personal and other datacollected and stored by Gusto (e.g., salary information, etc.) may betransferred to a company banking system, to QuickBooks, and/or to an HRfile cabinet.

As may be understood from the example shown in FIG. 5 , the system maybe configured to generate a data model based around Gusto thatillustrates a flow of personal data utilized by Gusto. The data model inthis example illustrates, for example, a source of personal datacollected, stored and/or processed by Gusto, a destination of such data,an indication of who has access to such data within Gusto, and anorganization and department responsible for the information collected byGusto. In particular embodiments, the data model and accompanying visualrepresentation (e.g., data map) generated by the system as described inany embodiment herein may be utilized in the context of compliance withone or more record keeping requirements related to the collection,storage, and processing of personal data.

FIGS. 6 and 7 depict an exemplary data model and related example that issimilar, in some respects, to the data model and example of FIGS. 4 and5 . In the example shown in FIGS. 6 and 7 , the exemplary data model andrelated example include a specific business process and processingactivity that is associated with the primary asset (Gusto). In thisexample, the business process is compensation and the specificprocessing activity is direct deposit generation in Gusto. As may beunderstood from this figure, the collection and transfer of data relatedto the storage asset of Gusto is based on a need to generate directdeposits through Gusto in order to compensate employees. Gusto generatesthe information needed to conduct a direct deposit (e.g., financial andsalary information) and then transmits this information to: (1) acompany bank system for execution of the direct deposit; (2) Quickbooksfor use in documenting the direct deposit payment; and (3) HR Filecabinet for use in documenting the salary info and other financialinformation.

As may be understood in light of this disclosure, when generating such adata model, particular pieces of data (e.g., data attributes, dataelements) may not be readily available to the system. In suchembodiment, the system is configured to identify a particular type ofdata, create a placeholder for such data in memory, and seek out (e.g.,scan for and populate) an appropriate piece of data to further populatethe data model. For example, in particular embodiments, the system mayidentify Gusto as a primary asset and recognize that Gusto storesexpense information. The system may then be configured to identify asource of the expense information (e.g., Expensify).

FIG. 8 depicts an exemplary screen display 800 that illustrates a visualrepresentation (e.g., visual data map) of a data model (e.g., a datainventory). In the example shown in FIG. 8 , the data map provides avisual indication of a flow of data collected from particular datasubjects (e.g., employees 801). As may be understood from this figure,the data map illustrates that three separate data assets receive data(e.g., which may include personal data) directly from the employees 801.In this example, these three data assets include Kronos 803 (e.g., ahuman resources software application), Workday 805 (e.g., a humanresources software application), and ADP 807 (e.g., a human resourcessoftware application and payment processor). As shown in FIG. 8 , thetransfer of data from the employees 801 to these assets is indicated byrespective arrows.

As further illustrated in FIG. 8 , the data map indicates a transfer ofdata from Workday 805 to ADP 807 as well as to a Recovery Datacenter 809and a London HR File Center 811. As may be understood in light of thisdisclosure, the Recovery Datacenter 809 and London HR File Center 811may comprise additional data assets in the context of the data modelillustrated by the data map shown in FIG. 8 . The Recover Datacenter 809may include, for example, one or more computer servers (e.g., backupservers). The London HR File Center 811 may include, for example, one ormore databases (e.g., such as the One or More Databases 140 shown inFIG. 1 ). AS shown in FIG. 8 , each particular data asset depicted inthe data map may be shown along with a visual indication of the type ofdata asset. For example, Kronos 803, Workday 805, and ADP 807 aredepicted adjacent a first icon type (e.g., a computer monitor), whileRecover Datacenter 809 and London HR File Center 811 are depictedadjacent a second and third icon type respectively (e.g., a servercluster and a file folder). In this way, the system may be configured tovisually indicate, via the data model, particular information related tothe data model in a relatively minimal manner.

FIG. 9 depicts an exemplary screen display 900 that illustrates a datamap of a plurality of assets 905 in tabular form (e.g., table form). Asmay be understood from this figure, a table that includes one or moreinventory attributes of each particular asset 905 in the table mayindicate, for example: (1) a managing organization 910 of eachrespective asset 905; (2) a hosting location 915 of each respectiveasset 905 (e.g., a physical storage location of each asset 905); (3) atype 920 of each respective asset 905, if known (e.g., a database,software application, server, etc.); (4) a processing activity 925associated with each respective asset 905; and/or (5) a status 930 ofeach particular data asset 905. In various embodiments, the status 930of each particular asset 905 may indicate a status of the asset 905 inthe discovery process. This may include, for example: (1) a “new” statusfor a particular asset that has recently been discovered as an assetthat processes, stores, or collects personal data on behalf of anorganization (e.g., discovered via one or more suitable techniquesdescribed herein); (2) an “in discovery” status for a particular assetfor which the system is populating or seeking to populate one or moreinventory attributes, etc.

FIG. 10 depicts an exemplary data map 1000 that includes an asset map ofa plurality of data assets 1005A-F, which may, for example, be utilizedby a particular entity in the collection, storage, and/or processing ofpersonal data. As may be understood in light of this disclosure, theplurality of data assets 1005A-F may have been discovered using anysuitable technique described herein (e.g., one or more intelligentidentity scanning techniques, one or more questionnaires, one or moreapplication programming interfaces, etc.). In various embodiments, adata inventory for each of the plurality of data assets 1005A-F maydefine, for each of the plurality of data assets 1005A-F a respectiveinventory attribute related to a storage location of the data asset.

As may be understood from this figure, the system may be configured togenerate a map that indicates a location of the plurality of data assets1005A-F for a particular entity. In the embodiment shown in this figure,locations that contain a data asset are indicated by circular indiciathat contain the number of assets present at that location. In theembodiment shown in this figure, the locations are broken down bycountry. In particular embodiments, the asset map may distinguishbetween internal assets (e.g., first party servers, etc.) andexternal/third party assets (e.g., third party owned servers or softwareapplications that the entity utilizes for data storage, transfer, etc.).

In some embodiments, the system is configured to indicate, via thevisual representation, whether one or more assets have an unknownlocation (e.g., because the data model described above may be incompletewith regard to the location). In such embodiments, the system may beconfigured to: (1) identify the asset with the unknown location; (2) useone or more data modeling techniques described herein to determine thelocation (e.g., such as pinging the asset, generating one or morequestionnaires for completion by a suitable individual, etc.); and (3)update a data model associated with the asset to include the location.

Data Model Population Module

In particular embodiments, a Data Model Population Module 1100 isconfigured to: (1) determine one or more unpopulated inventoryattributes in a data model; (2) determine one or more attribute valuesfor the one or more unpopulated inventory attributes; and (3) modify thedata model to include the one or more attribute values.

Turning to FIG. 11 , in particular embodiments, when executing the DataModel Population Module 1100, the system begins, at Step 1110, byanalyzing one or more data inventories for each of the one or more dataassets in the data model. The system may, for example, identify one ormore particular data elements (e.g., inventory attributes) that make upthe one or more data inventories. The system may, in variousembodiments, scan one or more data structures associated with the datamodel to identify the one or more data inventories. In variousembodiments, the system is configured to build an inventory of existing(e.g., known) data assets and identify inventory attributes for each ofthe known data assets.

Continuing to Step 1120, the system is configured to determine, for eachof the one or more data inventories, one or more populated inventoryattributes and one or more unpopulated inventory attributes (e.g.,and/or one or more unpopulated data assets within the data model). As aparticular example related to an unpopulated data asset, when generatingand populating a data model, the system may determine that, for aparticular asset, there is a destination asset. In various embodiments,the destination asset may be known (e.g., and already stored by thesystem as part of the data model). In other embodiments, the destinationasset may be unknown (e.g., a data element that comprises thedestination asset may comprise a placeholder or other indication inmemory for the system to populate the unpopulated inventory attribute(e.g., data element).

As another particular example, a particular storage asset may beassociated with a plurality of inventory assets (e.g., stored in a datainventory associated with the storage asset). In this example, theplurality of inventory assets may include an unpopulated inventoryattribute related to a type of personal data stored in the storageasset. The system may, for example, determine that the type of personaldata is an unpopulated inventory asset for the particular storage asset.

Returning to Step 1130, the system is configured to determine, for eachof the one or more unpopulated inventory attributes, one or moreattribute values. In particular embodiments, the system may determinethe one or more attribute values using any suitable technique (e.g., anysuitable technique for populating the data model). In particularembodiments, the one or more techniques for populating the data modelmay include, for example: (1) obtaining data for the data model by usingone or more questionnaires associated with a particular privacycampaign, processing activity, etc.; (2) using one or more intelligentidentity scanning techniques discussed herein to identify personal datastored by the system and then map such data to a suitable data model;(3) using one or more application programming interfaces (API) to obtaindata for the data model from another software application; and/or (4)using any other suitable technique. Exemplary techniques for determiningthe one or more attribute values are described more fully below. Inother embodiments, the system may be configured to use such techniquesor other suitable techniques to populate one or more unpopulated dataassets within the data model.

Next, at Step 1140, the system modifies the data model to include theone or more attribute values for each of the one or more unpopulatedinventory attributes. The system may, for example, store the one or moreattributes values in computer memory, associate the one or moreattribute values with the one or more unpopulated inventory attributes,etc. In still other embodiments, the system may modify the data model toinclude the one or more data assets identified as filling one or morevacancies left within the data model by the unpopulated one or more dataassets.

Continuing to Step 1150, the system is configured to store the modifieddata model in memory. In various embodiments, the system is configuredto store the modified data model in the One or More Databases 140, or inany other suitable location. In particular embodiments, the system isconfigured to store the data model for later use by the system in theprocessing of one or more data subject access requests. In otherembodiments, the system is configured to store the data model for use inone or more privacy impact assessments performed by the system.

Data Model Population Questionnaire Generation Module

In particular embodiments, a Data Population Questionnaire GenerationModule 1200 is configured to generate a questionnaire (e.g., one or morequestionnaires) comprising one or more questions associated with one ormore particular unpopulated data attributes, and populate theunpopulated data attributes based at least in part on one or moreresponses to the questionnaire. In other embodiments, the system may beconfigured to populate the unpopulated data attributes based on one ormore responses to existing questionnaires.

In various embodiments, the one or more questionnaires may comprise oneor more processing activity questionnaires (e.g., privacy impactassessments, data privacy impact assessments, etc.) configured to elicitone or more pieces of data related to one or more undertakings by anorganization related to the collection, storage, and/or processing ofpersonal data (e.g., processing activities). In particular embodiments,the system is configured to generate the questionnaire (e.g., aquestionnaire template) based at least in part on one or more processingactivity attributes, data asset attributes (e.g., inventory attributes),or other suitable attributes discussed herein.

Turning to FIG. 12 , in particular embodiments, when executing the DataPopulation Questionnaire Generation Module 1200, the system begins, atStep 1210, by identifying one or more unpopulated data attributes from adata model. The system may, for example, identify the one or moreunpopulated data attributes using any suitable technique describedabove. In particular embodiments, the one or more unpopulated dataattributes may relate to, for example, one or more processing activityor asset attributes such as: (1) one or more processing activitiesassociated with a particular data asset; (2) transfer data associatedwith the particular data asset (e.g., how and where the data storedand/or collected by the particular data asset is being transferred toand/or from); (3) personal data associated with the particular dataassets asset (e.g., what type of personal data is collected and/orstored by the particular data asset; how, and from where, the data iscollected, etc.); (4) storage data associated with the personal data(e.g., whether the data is being stored, protected and deleted); and (5)any other suitable attribute related to the collection, use, andtransfer of personal data by one or more data assets or via one or moreprocessing activities. In other embodiments, the one or more unpopulatedinventory attributes may comprise one or more other pieces ofinformation such as, for example: (1) the type of data being stored bythe particular data asset; (2) an amount of data stored by theparticular data asset; (3) whether the data is encrypted by theparticular data asset; (4) a location of the stored data (e.g., aphysical location of one or more computer servers on which the data isstored by the particular data asset); etc.

Continuing to Step 1220, the system generates a questionnaire (e.g., aquestionnaire template) comprising one or more questions associated withone or more particular unpopulated data attributes. As may be understoodin light of the above, the one or more particulate unpopulated dataattributes may relate to, for example, a particular processing activityor a particular data asset (e.g., a particular data asset utilized aspart of a particular processing activity). In various embodiments, theone or more questionnaires comprise one or more questions associatedwith the unpopulated data attribute. For example, if the data modelincludes an unpopulated data attribute related to a location of a serveron which a particular asset stores personal data, the system maygenerate a questionnaire associated with a processing activity thatutilizes the asset (e.g., or a questionnaire associated with the asset).The system may generate the questionnaire to include one or morequestions regarding the location of the server.

Returning to Step 1230, the system maps one or more responses to the oneor more questions to the associated one or more particular unpopulateddata attributes. The system may, for example, when generating thequestionnaire, associate a particular question with a particularunpopulated data attribute in computer memory. In various embodiments,the questionnaire may comprise a plurality of question/answer pairings,where the answer in the question/answer pairings maps to a particularinventory attribute for a particular data asset or processing activity.

In this way, the system may, upon receiving a response to the particularquestion, substantially automatically populate the particularunpopulated data attribute. Accordingly, at Step 1240, the systemmodifies the data model to populate the one or more responses as one ormore data elements for the one or more particular unpopulated dataattributes. In particular embodiments, the system is configured tomodify the data model such that the one or more responses are stored inassociation with the particular data element (e.g., unpopulated dataattribute) to which the system mapped it at Step 1230. In variousembodiments, the system is configured to store the modified data modelin the One or More Databases 140, or in any other suitable location. Inparticular embodiments, the system is configured to store the data modelfor later use by the system in the processing of one or more datasubject access requests. In other embodiments, the system is configuredto store the data model for use in one or more privacy impactassessments performed by the system.

Continuing to optional Step 1250, the system may be configured to modifythe questionnaire based at least in part on the one or more responses.The system may, for example, substantially dynamically add and/or removeone or more questions to/from the questionnaire based at least in parton the one or more responses (e.g., one or more response received by auser completing the questionnaire). For example, the system may, inresponse to the user providing a particular inventory attribute or newasset, generates additional questions that relate to that particularinventory attribute or asset. The system may, as the system addsadditional questions, substantially automatically map one or moreresponses to one or more other inventory attributes or assets. Forexample, in response to the user indicating that personal data for aparticular asset is stored in a particular location, the system maysubstantially automatically generate one or more additional questionsrelated to, for example, an encryption level of the storage, who hasaccess to the storage location, etc.

In still other embodiments, the system may modify the data model toinclude one or more additional assets, data attributes, inventoryattributes, etc. in response to one or more questionnaire responses. Forexample, the system may modify a data inventory for a particular assetto include a storage encryption data element (which specifies whetherthe particular asset stores particular data in an encrypted format) inresponse to receiving such data from a questionnaire. Modification of aquestionnaire is discussed more fully below with respect to FIG. 13 .

Data Model Population Via Questionnaire Process Flow

FIG. 13 depicts an exemplary process flow 1300 for populating a datamodel (e.g., modifying a data model to include a newly discovered dataasset, populating one or more inventory attributes for a particularprocessing activity or data asset, etc.). In particular, FIG. 13 depictsone or more exemplary data relationships between one or more particulardata attributes (e.g., processing activity attributes and/or assetattributes), a questionnaire template (e.g., a processing activitytemplate and/or a data asset template), a completed questionnaire (e.g.,a processing activity assessment and/or a data asset assessment), and adata inventory (e.g., a processing activity inventory and/or an assetinventory). As may be understood from this figure the system isconfigured to: (1) identify new data assets; (2) generate an assetinventory for identified new data assets; and (3) populate the generatedasset inventories. Systems and methods for populating the generatedinventories are described more fully below.

As may be understood from FIG. 13 , a system may be configured to mapparticular processing activity attributes 1320A to each of: (1) aprocessing activity template 1330A; and (2) a processing activity datainventory 1310A. As may be understood in light of this disclosure, theprocessing activity template 1330A may comprise a plurality of questions(e.g., as part of a questionnaire), which may, for example, beconfigured to elicit discovery of one or more new data assets. Theplurality of questions may each correspond to one or more fields in theprocessing activity inventory 1310A, which may, for example, define oneor more inventory attributes of the processing activity.

In particular embodiments, the system is configured to provide aprocessing activity assessment 1340A to one or more individuals forcompletion. As may be understood from FIG. 13 , the system is configuredto launch the processing activity assessment 1340A from the processingactivity inventory 1310A and further configured to create the processingactivity assessment 1340A from the processing activity template 1330.The processing activity assessment 1340A may comprise, for example, oneor more questions related to the processing activity. The system may, invarious embodiments, be configured to map one or more responses providedin the processing activity assessment 1340A to one or more correspondingfields in the processing activity inventory 1310A. The system may thenbe configured to modify the processing activity inventory 1310A toinclude the one or more responses, and store the modified inventory incomputer memory. In various embodiments, the system may be configured toapprove a processing activity assessment 1340A (e.g., receive approvalof the assessment) prior to feeding the processing activity inventoryattribute values into one or more fields and/or cells of the inventory.

As may be further understood from FIG. 13 , in response to creating anew asset record (e.g., which the system may create, for example, inresponse to a new asset discovery via the processing activity assessment1340A described immediately above, or in any other suitable manner), thesystem may generate an asset inventory 1310B (e.g., a data assetinventory) that defines a plurality of inventory attributes for the newasset (e.g., new data asset).

As may be understood from FIG. 13 , a system may be configured to mapparticular asset attributes 1320B to each of: (1) an asset template1330BA; and (2) an asset inventory 1310A. As may be understood in lightof this disclosure, the asset template 1330B may comprise a plurality ofquestions (e.g., as part of a questionnaire), which may, for example, beconfigured to elicit discovery of one or more processing activitiesassociated with the asset and/or one or more inventory attributes of theasset. The plurality of questions may each correspond to one or morefields in the asset inventory 1310B, which may, for example, define oneor more inventory attributes of the asset.

In particular embodiments, the system is configured to provide an assetassessment 1340B to one or more individuals for completion. As may beunderstood from FIG. 13 , the system is configured to launch the assetassessment 1340B from the asset inventory 1310B and further configuredto create the asset assessment 1340B from the asset template 1330B. Theasset assessment 1340B may comprise, for example, one or more questionsrelated to the data asset. The system may, in various embodiments, beconfigured to map one or more responses provided in the asset assessment1340B to one or more corresponding fields in the asset inventory 1310B.The system may then be configured to modify the asset inventory 1310B(e.g., and/or a related processing activity inventory 1310A) to includethe one or more responses, and store the modified inventory in computermemory. In various embodiments, the system may be configured to approvean asset assessment 1340B (e.g., receive approval of the assessment)prior to feeding the asset inventory attribute values into one or morefields and/or cells of the inventory.

FIG. 13 further includes a detail view 1350 of a relationship betweenparticular data attributes 1320C with an exemplary data inventory 1310Cand a questionnaire template 1330C. As may be understood from thisdetail view 1350, a particular attribute name may map to a particularquestion title in a template 1330C as well as to a field name in anexemplary data inventory 1310C. In this way, the system may beconfigured to populate (e.g., automatically populate) a field name for aparticular inventory 1310C in response to a user providing a questiontitle as part of a questionnaire template 1330C. Similarly, a particularattribute description may map to a particular question description in atemplate 1330C as well as to a tooltip on a fieldname in an exemplarydata inventory 1310C. In this way, the system may be configured toprovide the tooltip for a particular inventory 1310C that includes thequestion description provided by a user as part of a questionnairetemplate 1330C.

As may be further understood from the detail view 1350 of FIG. 13 , aparticular response type may map to a particular question type in atemplate 1330C as well as to a field type in an exemplary data inventory1310C. A particular question type may include, for example, a multiplechoice question (e.g., A, B, C, etc.), a freeform response, an integervalue, a drop down selection, etc. A particular field type may include,for example, a memo field type, a numeric field type, an integer fieldtype, a logical field type, or any other suitable field type. Aparticular data attribute may require a response type of, for example:(1) a name of an organization responsible for a data asset (e.g., a freeform response); (2) a number of days that data is stored by the dataasset (e.g., an integer value); and/or (3) any other suitable responsetype.

In still other embodiments, the system may be configured to map a one ormore attribute values to one or more answer choices in a template 1330Cas well as to one or more lists and/or responses in a data inventory1310C. The system may then be configured to populate a field in the datainventory 1310C with the one or more answer choices provided in aresponse to a question template 1330C with one or more attribute values.

Exemplary Questionnaire Generation and Completion User Experience

FIGS. 14-25 depict exemplary screen displays that a user may encounterwhen generating a questionnaire (e.g., one or more questionnaires and/ortemplates) for populating one or more data elements (e.g., inventoryattributes) of a data model for a data asset and/or processing activity.FIG. 14 , for example, depicts an exemplary asset based questionnairetemplate builder 1400. As may be understood from FIG. 14 , the templatebuilder may enable a user to generate an asset based questionnairetemplate that includes one or more sections 1420 related to the asset(e.g., asset information, security, disposal, processing activities,etc.). As may be understood in light of this disclosure, the system maybe configured to substantially automatically generate an asset basedquestionnaire template based at least in part on the one or moreunpopulated inventory attributes discussed above. The system may, forexample, be configured to generate a template that is configured topopulate the one or more unpopulated attributes (e.g., by elicitingresponses, via a questionnaire to one or more questions that are mappedto the attributes within the data inventory).

In various embodiments, the system is configured to enable a user tomodify a default template (e.g., or a system-created template) by, forexample, adding additional sections, adding one or more additionalquestions to a particular section, etc. In various embodiments, thesystem may provide one or more tools for modifying the template. Forexample, in the embodiment shown in FIG. 14 , the system may provide auser with a draft and drop question template 1410, from which the usermay select a question type (e.g., textbox, multiple choice, etc.).

A template for an asset may include, for example: (1) one or morequestions requesting general information about the asset; (2) one ormore security-related questions about the asset; (3) one or morequestions regarding how the data asset disposes of data that it uses;and/or (4) one or more questions regarding processing activities thatinvolve the data asset. In various embodiments, each of these one ormore sections may comprise one or more specific questions that may mapto particular portions of a data model (e.g., a data map).

FIG. 15 depicts an exemplary screen display of a processing activityquestionnaire template builder 1500. The screen display shown in FIG. 15is similar to the template builder shown in FIG. 14 with respect to thedata asset based template builder. As may be understood from FIG. 15 ,the template builder may enable a user to generate a processing activitybased questionnaire template that includes one or more sections 1520related to the processing activity (e.g., business process information,personal data, source, storage, destinations, access and use, etc.). Asmay be understood in light of this disclosure, the system may beconfigured to substantially automatically generate a processing activitybased questionnaire template based at least in part on the one or moreunpopulated inventory attributes related to the processing activity(e.g., as discussed above). The system may, for example, be configuredto generate a template that is configured to populate the one or moreunpopulated attributes (e.g., by eliciting responses, via aquestionnaire to one or more questions that are mapped to the attributeswithin the data inventory).

In various embodiments, the system is configured to enable a user tomodify a default template (e.g., or a system-created template) by, forexample, adding additional sections, adding one or more additionalquestions to a particular section, etc. In various embodiments, thesystem may provide one or more tools for modifying the template. Forexample, in the embodiment shown in FIG. 15 , the system may provide auser with a draft and drop question template 1510, from which the usermay select a question type (e.g., textbox, multiple choice, assetattributes, data subjects, etc.). The system may be further configuredto enable a user to publish a completed template (e.g., for use in aparticular assessment). In other embodiments, the system may beconfigured to substantially automatically publish the template.

In various embodiments, a template for a processing activity mayinclude, for example: (1) one or more questions related to the type ofbusiness process that involves a particular data asset; (2) one or morequestions regarding what type of personal data is acquired from datasubjects for use by a particular data asset; (3) one or more questionsrelated to a source of the acquired personal data; (4) one or morequestions related to how and/or where the personal data will be storedand/or for how long; (5) one or more questions related to one or moreother data assets that the personal data will be transferred to; and/or(6) one or more questions related to who will have the ability to accessand/or use the personal data.

Continuing to FIG. 16 , an exemplary screen display 1600 depicts alisting of assets 1610 for a particular entity. These may, for example,have been identified as part of the data model generation systemdescribed above. As may be understood from this figure, a user mayselect a drop down indicator 1615 to view more information about aparticular asset. In the exemplary embodiment shown in FIG. 16 , thesystem stores the managing organization group for the “New Asset”, butis missing some additional information (e.g., such as a description 1625of the asset). In order to fill out the missing inventory attributes forthe “New Asset”, the system, in particular embodiments, is configured toenable a user to select a Send Assessment indicia 1620 in order totransmit an assessment related to the selected asset to an individualtasked with providing one or more pieces of information related to theasset (e.g., a manager, or other individual with knowledge of the one ormore inventory attributes).

In response to the user selecting the Send Assessment indicia 1620, thesystem may create the assessment based at least in part on a templateassociated with the asset, and transmit the assessment to a suitableindividual for completion (e.g., and/or transmit a request to theindividual to complete the assessment).

FIG. 17 depicts an exemplary assessment transmission interface 1700 viawhich a user can transmit one or more assessments for completion. Asshown in this figure, the user may assign a respondent, provide adeadline, indicate a reminder time, and provide one or more commentsusing an assessment request interface 1710. The user may then select aSend Assessment(s) indicia 1720 in order to transmit the assessment.

FIG. 18 depicts an exemplary assessment 1800 which a user may encounterin response to receiving a request to complete the assessment asdescribed above with respect to FIGS. 16 and 17 . As shown in FIG. 18 ,the assessment 1800 may include one or more questions that map to theone or more unpopulated attributes for the asset shown in FIG. 16 . Forexample, the one or more questions may include a question related to adescription of the asset, which may include a free form text box 1820for providing a description of the asset. FIG. 19 depicts an exemplaryscreen display 1900 with the text box 1920 completed, where thedescription includes a value of “Value_1”. As shown in FIGS. 18 and 19 ,the user may have renamed “New Asset” (e.g., which may have included adefault or placeholder name) shown in FIGS. 16 and 17 to “7^(th) Asset.”

Continuing to FIG. 20 , the exemplary screen display 2000 depicts thelisting of assets 2010 from FIG. 16 with some additional attributespopulated. For example, the Description 2025 (e.g., “Value_1”) providedin FIG. 19 has been added to the inventory. As may be understood inlight of this disclosure, in response to a user providing thedescription via the assessment shown in FIGS. 18 and 19 , the system maybe configured to map the provided description to the attribute valueassociated with the description of the asset in the data inventory. Thesystem may have then modified the data inventory for the asset toinclude the description attribute. In various embodiments, the system isconfigured to store the modified data inventory as part of a data model(e.g., in computer memory).

FIGS. 21-24 depict exemplary screen displays showing exemplary questionsthat make up part of a processing activity questionnaire (e.g.,assessment). FIG. 21 depicts an exemplary interface 2100 for respondingto a first question 2110 and a second question 2120. As shown in FIG. 21, the first question 2110 relates to whether the processing activity isa new or existing processing activity. The first question 2110 shown inFIG. 21 is a multiple choice question. The second question 2120 relatesto whether the organization is conducting the activity on behalf ofanother organization. As shown in this figure, the second question 2120includes both a multiple choice portion and a free-form responseportion.

As discussed above, in various embodiments, the system may be configuredto modify a questionnaire in response to (e.g., based on) one or moreresponses provided by a user completing the questionnaire. In particularembodiments, the system is configured to modify the questionnairesubstantially on-the-fly (e.g., as the user provides each particularanswer). FIG. 22 depicts an interface 2200 that includes a secondquestion 2220 that differs from the second question 2120 shown in FIG.21 . As may be understood in light of this disclosure, in response tothe user providing a response to the first question 2110 in FIG. 21 thatindicates that the processing activity is a new processing activity, thesystem may substantially automatically modify the second question 2120from FIG. 21 to the second question 2220 from FIG. 22 (e.g., such thatthe second question 2220 includes one or more follow up questions orrequests for additional information based on the response to the firstquestion 2110 in FIG. 21 ).

As shown in FIG. 22 , the second question 2220 requests a description ofthe activity that is being pursued. In various embodiments (e.g., suchas if the user had selected that the processing activity was an existingone), the system may not modify the questionnaire to include the secondquestion 2220 from FIG. 22 , because the system may already storeinformation related to a description of the processing activity atissue. In various embodiments, any suitable question described hereinmay include a tooltip 2225 on a field name (e.g., which may provide oneor more additional pieces of information to guide a user's response tothe questionnaire and/or assessment).

FIGS. 23 and 24 depict additional exemplary assessment questions. Thequestions shown in these figures relate to, for example, particular dataelements processed by various aspects of a processing activity.

FIG. 25 depicts a dashboard 2500 that includes an accounting of one ormore assessments that have been completed, are in progress, or requirecompletion by a particular organization. The dashboard 2500 shown inthis figure is configured to provide information relate to the status ofone or more outstanding assessments. As may be understood in light ofthis disclosure, because of the volume of assessment requests, it may benecessary to utilize one or more third party organizations to facilitatea timely completion of one or more assessment requests. In variousembodiments, the dashboard may indicate that, based on a fact that anumber of assessments are still in progress or incomplete, that aparticular data model for an entity, data asset, processing activity,etc. remains incomplete. In such embodiments, an incomplete nature of adata model may raise one or more flags or indicate a risk that an entitymay not be in compliance with one or more legal or industry requirementsrelated to the collection, storage, and/or processing of personal data.

Intelligent Identity Scanning Module

Turning to FIG. 26 , in particular embodiments, the Intelligent IdentityScanning Module 2600 is configured to scan one or more data sources toidentify personal data stored on one or more network devices for aparticular organization, analyze the identified personal data, andclassify the personal data (e.g., in a data model) based at least inpart on a confidence score derived using one or more machine learningtechniques. The confidence score may be and/or comprise, for example, anindication of the probability that the personal data is actuallyassociated with a particular data subject (e.g., that there is at leastan 80% confidence level that a particular phone number is associatedwith a particular individual.)

When executing the Intelligent Identity Scanning Module 2600, the systembegins, at Step 2610, by connecting to one or more databases or otherdata structures, and scanning the one or more databases to generate acatalog of one or more individuals and one or more pieces of personalinformation associated with the one or more individuals. The system may,for example, be configured to connect to one or more databasesassociated with a particular organization (e.g., one or more databasesthat may serve as a storage location for any personal or other datacollected, processed, etc. by the particular organization, for example,as part of a suitable processing activity. As may be understood in lightof this disclosure, a particular organization may use a plurality of oneor more databases (e.g., the One or More Databases 140 shown in FIG. 1), a plurality of servers (e.g., the One or More Third Party Servers 160shown in FIG. 1 ), or any other suitable data storage location in orderto store personal data and other data collected as part of any suitableprivacy campaign, privacy impact assessment, processing activity, etc.

In particular embodiments, the system is configured to scan the one ormore databases by searching for particular data fields comprising one ormore pieces of information that may include personal data. The systemmay, for example, be configured to scan and identify one of more piecesof personal data such as: (1) name; (2) address; (3) telephone number;(4) e-mail address; (5) social security number; (6) informationassociated with one or more credit accounts (e.g., credit card numbers);(7) banking information; (8) location data; (9) internet search history;(10) non-credit account data; and/or (11) any other suitable personalinformation discussed herein. In particular embodiments, the system isconfigured to scan for a particular type of personal data (e.g., or oneor more particular types of personal data).

The system may, in various embodiments, be further configured togenerate a catalog of one or more individuals that also includes one ormore pieces of personal information (e.g., personal data) identified forthe individuals during the scan. The system may, for example, inresponse to discovering one or more pieces of personal data in aparticular storage location, identify one or more associations betweenthe discovered pieces of personal data. For example, a particulardatabase may store a plurality of individuals' names in association withtheir respective telephone numbers. One or more other databases mayinclude any other suitable information.

The system may, for example, generate the catalog to include anyinformation associated with the one or more individuals identified inthe scan. The system may, for example, maintain the catalog in anysuitable format (e.g., a data table, etc.).

In still other embodiments, in addition to connecting to a database, thesystem may be configured to: (1) access an application through one ormore application programming interfaces (APIs); (2) use one or morescreen scraping techniques on an end user page to identify and analyzeeach field on the page; and/or (3) connect to any other suitable datastructure in order to generate the catalog of individuals and personalinformation associated with each of the individuals. In someembodiments, the system may be configured to analyze one or more accesslogs and applications set up through a system active directory or SSOportal for which one or more applications might contain certain data foruser groups. The system may then be configured to analyze an emailenvironment to identify one or more links to particular businessapplications, which may, for example, be in use by an entity and containcertain data. In still other embodiments, the system may be configuredto analyze one or more system log files (Syslog) from a securityenvironment to capture which particular applications an entity may beusing in order to discover such applications.

Continuing to Step 2620, the system is configured to scan one or morestructured and/or unstructured data repositories based at least in parton the generated catalog to identify one or more attributes of dataassociated with the one or more individuals. The system may, forexample, be configured to utilize information discovered during theinitial scan at Step 2610 to identify the one or more attributes of dataassociated with the one or more individuals.

For example, the catalog generated at Step 2610 may include a name,address, and phone number for a particular individual. The system may beconfigured, at Step 2620, to scan the one or more structured and/orunstructured data repositories to identify one or more attributes thatare associated with one or more of the particular individual's name,address and/or phone number. For example, a particular data repositorymay store banking information (e.g., a bank account number and routingnumber for the bank) in association with the particular individual'saddress. In various embodiments, the system may be configured toidentify the banking information as an attribute of data associated withthe particular individual. In this way, the system may be configured toidentify particular data attributes (e.g., one or more pieces ofpersonal data) stored for a particular individual by identifying theparticular data attributes using information other than the individual'sname.

Returning to Step 2630, the system is configured to analyze andcorrelate the one or more attributes and metadata for the scanned one ormore structured and/or unstructured data repositories. In particularembodiments, the system is configured to correlate the one or moreattributes with metadata for the associated data repositories from whichthe system identified the one or more attributes. In this way, thesystem may be configured to store data regarding particular datarepositories that store particular data attributes.

In particular embodiments, the system may be configured tocross-reference the data repositories that are discovered to store oneor more attributes of personal data associated with the one or moreindividuals with a database of known data assets. In particularembodiments, the system is configured to analyze the data repositoriesto determine whether each data repository is part of an existing datamodel of data assets that collect, store, and/or process personal data.In response to determining that a particular data repository is notassociated with an existing data model, the system may be configured toidentify the data repository as a new data asset (e.g., via assetdiscovery), and take one or more actions (e.g., such as any suitableactions described herein) to generate and populate a data model of thenewly discovered data asset. This may include, for example: (1)generating a data inventory for the new data asset; (2) populating thedata inventory with any known attributes associated with the new dataasset; (3) identifying one or more unpopulated (e.g., unknown)attributes of the data asset; and (4) taking any suitable actiondescribed herein to populate the unpopulated data attributes.

In particular embodiments, the system my, for example: (1) identify asource of the personal data stored in the data repository that led tothe new asset discovery; (2) identify one or more relationships betweenthe newly discovered asset and one or more known assets; and/or (3) etc.

Continuing to Step 2640, the system is configured to use one or moremachine learning techniques to categorize one or more data elements fromthe generated catalog, analyze a flow of the data among the one or moredata repositories, and/or classify the one or more data elements basedon a confidence score as discussed below.

Continuing to Step 2650, the system, in various embodiments, isconfigured to receive input from a user confirming or denying acategorization of the one or more data elements, and, in response,modify the confidence score. In various embodiments, the system isconfigured to iteratively repeat Steps 2640 and 2650. In this way, thesystem is configured to modify the confidence score in response to auser confirming or denying the accuracy of a categorization of the oneor more data elements. For example, in particular embodiments, thesystem is configured to prompt a user (e.g., a system administrator,privacy officer, etc.) to confirm that a particular data element is, infact, associated with a particular individual from the catalog. Thesystem may, in various embodiments, be configured to prompt a user toconfirm that a data element or attribute discovered during one or moreof the scans above were properly categorized at Step 2640.

In particular embodiments, the system is configured to modify theconfidence score based at least in part on receiving one or moreconfirmations that one or more particular data elements or attributesdiscovered in a particular location during a scan are associated withparticular individuals from the catalog. As may be understood in lightof this disclosure, the system may be configured to increase theconfidence score in response to receiving confirmation that particulartypes of data elements or attributes discovered in a particular storagelocation are typically confirmed as being associated with particularindividuals based on one or more attributes for which the system wasscanning.

Exemplary Intelligent Identity Scanning Technical Platforms

FIG. 27 depicts an exemplary technical platform via which the system mayperform one or more of the steps described above with respect to theIntelligent Identity Scanning Module 2600. As shown in the embodiment inthis figure, an Intelligent Identity Scanning System 2600 comprises anIntelligent Identity Scanning Server 130, such as the IntelligentIdentity Scanning Server 130 described above with respect to FIG. 1 .The Intelligent Identity Scanning Server 130 may, for example, comprisea processing engine (e.g., one or more computer processors). In someembodiments, the Intelligent Identity Scanning Server 130 may includeany suitable cloud hosted processing engine (e.g., one or morecloud-based computer servers). In particular embodiments, theIntelligent Identity Scanning Server 130 is hosted in a Microsoft Azurecloud.

In particular embodiments, the Intelligent Identity Scanning Server 130is configured to sit outside one or more firewalls (e.g., such as thefirewall 195 shown in FIG. 26 ). In such embodiments, the IntelligentIdentity Scanning Server 130 is configured to access One or More RemoteComputing Devices 150 through the Firewall 195 (e.g., one or morefirewalls) via One or More Networks 115 (e.g., such as any of the One orMore Networks 115 described above with respect to FIG. 1 ).

In particular embodiments, the One or More Remote Computing Devices 150include one or more computing devices that make up at least a portion ofone or more computer networks associated with a particular organization.In particular embodiments, the one or more computer networks associatedwith the particular organization comprise one or more suitable servers,one or more suitable databases, one or more privileged networks, and/orany other suitable device and/or network segment that may store and/orprovide for the storage of personal data. In the embodiment shown inFIG. 27 , the one or more computer networks associated with theparticular organization may comprise One or More Third Party Servers160, One or More Databases 140, etc. In particular embodiments, the Oneor More Remote Computing Devices 150 are configured to access one ormore segments of the one or more computer networks associated with theparticular organization. In some embodiments, the one or more computernetworks associated with the particular organization comprise One orMore Privileged Networks 165. In still other embodiments, the one ormore computer networks comprise one or more network segments connectedvia one or more suitable routers, one or more suitable network hubs, oneor more suitable network switches, etc.

As shown in FIG. 27 , various components that make up one or more partsof the one or more computer networks associated with the particularorganization may store personal data (e.g., such as personal data storedon the One or More Third Party Servers 160, the One or More Databases140, etc.). In various embodiments, the system is configured to performone or more steps related to the Intelligent Identity Scanning Server2600 in order to identify the personal data for the purpose ofgenerating the catalog of individuals described above (e.g., and/oridentify one or more data assets within the organization's network thatstore personal data)

As further shown in FIG. 27 , in various embodiments, the One or MoreRemote Computing Devices 150 may store a software application (e.g., theIntelligent Identity Scanning Module). In such embodiments, the systemmay be configured to provide the software application for installationon the One or More Remote Computing Devices 150. In particularembodiments, the software application may comprise one or more virtualmachines. In particular embodiments, the one or more virtual machinesmay be configured to perform one or more of the steps described abovewith respect to the Intelligent Identity Scanning Module 2600 (e.g.,perform the one or more steps locally on the One or More RemoteComputing Devices 150).

In various embodiments, the one or more virtual machines may have thefollowing specifications: (1) any suitable number of cores (e.g., 4, 6,8, etc.); (2) any suitable amount of memory (e.g., 4 GB, 8 GB, 16 GBetc.); (3) any suitable operating system (e.g., CentOS 7.2); and/or (4)any other suitable specification. In particular embodiments, the one ormore virtual machines may, for example, be used for one or more suitablepurposes related to the Intelligent Identity Scanning System 2700. Theseone or more suitable purposes may include, for example, running any ofthe one or more modules described herein, storing hashed and/ornon-hashed information (e.g., personal data, personally identifiabledata, catalog of individuals, etc.), storing and running one or moresearching and/or scanning engines (e.g., Elasticsearch), etc.

In various embodiments, the Intelligent Identity Scanning System 2700may be configured to distribute one or more processes that make up partof the Intelligent Identity Scanning Process (e.g., described above withrespect to the Intelligent Identity Scanning Module 1800). The one ormore software applications installed on the One or more Remote ComputingDevices 150 may, for example, be configured to provide access to the oneor more computer networks associated with the particular organization tothe Intelligent Identity Scanning Server 130. The system may then beconfigured to receive, from the One or more Remote Computing Devices 150at the Intelligent Identity Scanning Server 130, via the Firewall 195and One or More Networks 115, scanned data for analysis.

In particular embodiments, the Intelligent Identity Scanning System 2700is configured to reduce an impact on a performance of the One or MoreRemote Computing Devices 150, One or More Third Party Servers 160 andother components that make up one or more segments of the one or morecomputer networks associated with the particular organization. Forexample, in particular embodiments, the Intelligent Identity ScanningSystem 2700 may be configured to utilize one or more suitable bandwidththrottling techniques. In other embodiments, the Intelligent IdentityScanning System 2700 is configured to limit scanning (e.g., any of theone or more scanning steps described above with respect to theIntelligent Identity Scanning Module 2600) and other processing steps(e.g., one or more steps that utilize one or more processing resources)to non-peak times (e.g., during the evening, overnight, on weekendsand/or holidays, etc.). In other embodiments, the system is configuredto limit performance of such processing steps to backup applications anddata storage locations. The system may, for example, use one or moresampling techniques to decrease a number of records required to scanduring the personal data discovery process.

FIG. 28 depicts an exemplary asset access methodology that the systemmay utilize in order to access one or more network devices that maystore personal data (e.g., or other personally identifiableinformation). As may be understood from this figure, the system may beconfigured to access the one or more network devices using a locallydeployed software application (e.g., such as the software applicationdescribed immediately above). In various embodiments, the softwareapplication is configured to route identity scanning traffic through oneor more gateways, configure one or more ports to accept one or moreidentity scanning connections, etc.

As may be understood from this figure, the system may be configured toutilize one or more credential management techniques to access one ormore privileged network portions. The system may, in response toidentifying particular assets or personally identifiable information viaa scan, be configured to retrieve schema details such as, for example,an asset ID, Schema ID, connection string, credential reference URL,etc. In this way, the system may be configured to identify and store alocation of any discovered assets or personal data during a scan.

Data Subject Access Request Fulfillment Module

Turning to FIG. 29 , in particular embodiments, a Data Subject AccessRequest Fulfillment Module 2900 is configured to receive a data subjectaccess request, process the request, and fulfill the request based atleast in part on one or more request parameters. In various embodiments,an organization, corporation, etc. may be required to provideinformation requested by an individual for whom the organization storespersonal data within a certain time period (e.g., 30 days). As aparticular example, an organization may be required to provide anindividual with a listing of, for example: (1) any personal data thatthe organization is processing for an individual, (2) an explanation ofthe categories of data being processed and the purpose of suchprocessing; and/or (3) categories of third parties to whom the data maybe disclosed.

Various privacy and security policies (e.g., such as the EuropeanUnion's General Data Protection Regulation, and other such policies) mayprovide data subjects (e.g., individuals, organizations, or otherentities) with certain rights related to the data subject's personaldata that is collected, stored, or otherwise processed by anorganization. These rights may include, for example: (1) a right toobtain confirmation of whether a particular organization is processingtheir personal data; (2) a right to obtain information about the purposeof the processing (e.g., one or more reasons for which the personal datawas collected); (3) a right to obtain information about one or morecategories of data being processed (e.g., what type of personal data isbeing collected, stored, etc.); (4) a right to obtain information aboutone or more categories of recipients with whom their personal data maybe shared (e.g., both internally within the organization or externally);(5) a right to obtain information about a time period for which theirpersonal data will be stored (e.g., or one or more criteria used todetermine that time period); (6) a right to obtain a copy of anypersonal data being processed (e.g., a right to receive a copy of theirpersonal data in a commonly used, machine-readable format); (7) a rightto request erasure (e.g., the right to be forgotten), rectification(e.g., correction or deletion of inaccurate data), or restriction ofprocessing of their personal data; and (8) any other suitable rightsrelated to the collection, storage, and/or processing of their personaldata (e.g., which may be provided by law, policy, industry ororganizational practice, etc.).

As may be understood in light of this disclosure, a particularorganization may undertake a plurality of different privacy campaigns,processing activities, etc. that involve the collection and storage ofpersonal data. In some embodiments, each of the plurality of differentprocessing activities may collect redundant data (e.g., may collect thesame personal data for a particular individual more than once), and maystore data and/or redundant data in one or more particular locations(e.g., on one or more different servers, in one or more differentdatabases, etc.). In this way, a particular organization may storepersonal data in a plurality of different locations which may includeone or more known and/or unknown locations. As such, complying withparticular privacy and security policies related to personal data (e.g.,such as responding to one or more requests by data subjects related totheir personal data) may be particularly difficult (e.g., in terms ofcost, time, etc.). In particular embodiments, a data subject accessrequest fulfillment system may utilize one or more data model generationand population techniques (e.g., such as any suitable techniquedescribed herein) to create a centralized data map with which the systemcan identify personal data stored, collected, or processed for aparticular data subject, a reason for the processing, and any otherinformation related to the processing.

Turning to FIG. 29 , when executing the Data Subject Access RequestFulfillment Module 2900, the system begins, at Step 2910, by receiving adata subject access request. In various embodiments, the system receivesthe request via a suitable web form. In certain embodiments, the requestcomprises a particular request to perform one or more actions with anypersonal data stored by a particular organization regarding therequestor. For example, in some embodiments, the request may include arequest to view one or more pieces of personal data stored by the systemregarding the requestor. In other embodiments, the request may include arequest to delete one or more pieces of personal data stored by thesystem regarding the requestor. In still other embodiments, the requestmay include a request to update one or more pieces of personal datastored by the system regarding the requestor. In still otherembodiments, the request may include a request based on any suitableright afforded to a data subject, such as those discussed above.

Continuing to Step 2920, the system is configured to process the requestby identifying and retrieving one or more pieces of personal dataassociated with the requestor that are being processed by the system.For example, in various embodiments, the system is configured toidentify any personal data stored in any database, server, or other datarepository associated with a particular organization. In variousembodiments, the system is configured to use one or more data models,such as those described above, to identify this personal data andsuitable related information (e.g., where the personal data is stored,who has access to the personal data, etc.). In various embodiments, thesystem is configured to use intelligent identity scanning (e.g., asdescribed above) to identify the requestor's personal data and relatedinformation that is to be used to fulfill the request.

In still other embodiments, the system is configured to use one or moremachine learning techniques to identify such personal data. For example,the system may identify particular stored personal data based on, forexample, a country in which a website that the data subject request wassubmitted is based, or any other suitable information.

In particular embodiments, the system is configured to scan and/orsearch one or more existing data models (e.g., one or more current datamodels) in response to receiving the request in order to identify theone or more pieces of personal data associated with the requestor. Thesystem may, for example, identify, based on one or more data inventories(e.g., one or more inventory attributes) a plurality of storagelocations that store personal data associated with the requestor. Inother embodiments, the system may be configured to generate a data modelor perform one or more scanning techniques in response to receiving therequest (e.g., in order to automatically fulfill the request).

Returning to Step 2930, the system is configured to take one or moreactions based at least in part on the request. In some embodiments, thesystem is configured to take one or more actions for which the requestwas submitted (e.g., display the personal data, delete the personaldata, correct the personal data, etc.). In particular embodiments, thesystem is configured to take the one or more actions substantiallyautomatically. In particular embodiments, in response a data subjectsubmitting a request to delete their personal data from anorganization's systems, the system may: (1) automatically determinewhere the data subject's personal data is stored; and (2) in response todetermining the location of the data (which may be on multiple computingsystems), automatically facilitate the deletion of the data subject'spersonal data from the various systems (e.g., by automatically assigninga plurality of tasks to delete data across multiple business systems toeffectively delete the data subject's personal data from the systems).In particular embodiments, the step of facilitating the deletion maycomprise, for example: (1) overwriting the data in memory; (2) markingthe data for overwrite; (2) marking the data as free (e.g., and deletinga directory entry associated with the data); and/or (3) any othersuitable technique for deleting the personal data. In particularembodiments, as part of this process, the system uses an appropriatedata model (see discussion above) to efficiently determine where all ofthe data subject's personal data is stored.

Data Subject Access Request User Experience

FIGS. 30-31 depict exemplary screen displays that a user may view whensubmitting a data subject access request. As shown in FIG. 30 , awebsite 30000 associated with a particular organization may include auser-selectable indicia 3005 for submitting a privacy-related request. Auser desiring to make such a request may select the indicia 3005 inorder to initiate the data subject access request process.

FIG. 31 depicts an exemplary data subject access request form in both anunfilled and filled out state. As shown in this figure, the system mayprompt a user to provide information such as, for example: (1) what typeof requestor the user is (e.g., employee, customer, etc.); (2) what therequest involves (e.g., requesting info, opting out, deleting data,updating data, etc.); (3) first name; (4) last name; (5) email address;(6) telephone number; (7) home address; and/or (8) one or more detailsassociated with the request.

As discussed in more detail above, a data subject may submit a subjectaccess request, for example, to request a listing of any personalinformation that a particular organization is currently storingregarding the data subject, to request that the personal data bedeleted, to opt out of allowing the organization to process the personaldata, etc.

Alternative Embodiments

In particular embodiments, a data modeling or other system describedherein may include one or more features in addition to those described.Various such alternative embodiments are described below.

Processing Activity and Data Asset Assessment Risk Flagging

In particular embodiments, the questionnaire template generation systemand assessment system described herein may incorporate one or more riskflagging systems. FIGS. 32-35 depict exemplary user interfaces thatinclude risk flagging of particular questions within a processingactivity assessment. As may be understood from these figures, a user mayselect a flag risk indicia to provide input related to a description ofrisks and mitigation of a risk posed by one or more inventory attributesassociated with the question. As shown in these figures, the system maybe configured to substantially automatically assign a risk to aparticular response to a question in a questionnaire. In variousembodiments, the assigned risk is determined based at least in part onthe template from which the assessment was generated.

In particular embodiments, the system may utilize the risk levelassigned to particular questionnaire responses as part of a riskanalysis of a particular processing activity or data asset. Varioustechniques for assessing the risk of various privacy campaigns aredescribed in U.S. patent application Ser. No. 15/256,419, filed Sep. 2,2016, entitled “Data processing systems and methods for operationalizingprivacy compliance and assessing the risk of various respective privacycampaigns,” which is hereby incorporated herein in its entirety.

Cross-Border Visualization Generation System

In particular embodiments, a Cross-Border Visualization GenerationSystem is configured to analyze one or more data systems (e.g., dataassets), identify data transfers between/among those systems, determinewhether any particular regulations apply to the identified datatransfers, and generate a visual representation of physical locations ofthe one or more data systems and the one or more data transfers betweenthem. The system may, for example, color-code one or more lines orindicators showing a transfer of data between a first and second datasystem. The one or more indicators may convey, for example: (1) whetherthe data transfer is secure; (2) a type or level of security that isapplied to the transfers; (3) one or more regulations that apply to thetransfer; and/or (4) any other suitable information related to thetransfer of particular data between the first and second data system.

Various processes performed by the Cross-Border Visualization GenerationSystem may be implemented by a Cross-Border Visualization GenerationModule 3600. Referring to FIG. 36 , in particular embodiments, thesystem, when executing the Cross-Border Visualization Generation Module3600, is configured to: (1) identify data systems associated with aparticular entity; (2) determine a location of the data systems; (3)identity one or more transfers of particular data elements betweenparticular data systems of the one or more data systems; (4) determineone or more regulations that relate to the one or more data transfers;and (5) generate a visual representation of the one or more datatransfers based at least in part on the one or more regulations.

When executing the Cross-Border Visualization Generation Module 3600,the system begins, at Step 3610, by identifying one or more data systems(e.g., data assets) associated with a particular entity. The particularentity may include, for example, a particular organization, company,sub-organization, etc. In particular embodiments, the one or more dataassets (e.g., data systems) may include, for example, any entity thatcollects, processes, contains, and/or transfers data (e.g., such as asoftware application, “internet of things” computerized device,database, website, data-center, server, etc.). For example, a first dataasset may include any software or device utilized by a particular entityfor such data collection, processing, transfer, storage, etc. In variousembodiments, the first data asset may be at least partially stored onand/or physically located in a particular location. For example, aserver may be located in a particular country, jurisdiction, etc. Apiece of software may be stored on one or more servers in a particularlocation, etc.

In particular embodiments, the system is configured to identify the oneor more data systems using one or more data modeling techniques. Asdiscussed more fully above, a data model may store the followinginformation: (1) the entity that owns and/or uses a particular dataasset (e.g., such as a primary data asset, an example of which is shownin the center of the data model in FIG. 4 ); (2) one or more departmentswithin the organization that are responsible for the data asset; (3) oneor more software applications that collect data (e.g., personal data)for storage in and/or use by the data asset; (4) one or more particulardata subjects (or categories of data subjects) that information iscollected from for use by the data asset; (5) one or more particulartypes of data that are collected by each of the particular applicationsfor storage in and/or use by the data asset; (6) one or more individuals(e.g., particular individuals or types of individuals) that arepermitted to access and/or use the data stored in, or used by, the dataasset; (7) which particular types of data each of those individuals areallowed to access and use; and (8) one or more data assets (destinationassets) that the data is transferred to for other use, and whichparticular data is transferred to each of those data assets.

As may be understood in light of this disclosure, the system may utilizea data model (e.g., or one or more data models) of data assetsassociated with a particular entity to identify the one or more datasystems associated with the particular entity.

Continuing to Step 3620, the system is configured to analyze the one ormore data assets (e.g., data systems) to identify one or more dataelements stored in the one or more identified data systems. Inparticular embodiments, the system is configured to identify one or moredata elements stored by the one or more data systems that are subject totransfer (e.g., transfer to the one or more data systems such as from asource asset, transfer from the one or more data systems to adestination asset, etc.). In particular embodiments, the system isconfigured to identify a particular data element that is subject to suchtransfer (e.g., such as a particular piece of personal data or otherdata). In some embodiments, the system may be configured to identify anysuitable data element that is subject to transfer and includes personaldata. The system may be configured to identify such transfer data usingany suitable technique described herein.

In any embodiment described herein, personal data may include, forexample: (1) the name of a particular data subject (which may be aparticular individual); (2) the data subject's address; (3) the datasubject's telephone number; (4) the data subject's e-mail address; (5)the data subject's social security number; (6) information associatedwith one or more of the data subject's credit accounts (e.g., creditcard numbers); (7) banking information for the data subject; (8)location data for the data subject (e.g., their present or pastlocation); (9) internet search history for the data subject; and/or (10)any other suitable personal information, such as other personalinformation discussed herein.

As may be understood from this disclosure, the transfer of personal datamay trigger one or more regulations that govern such transfer. Inparticular embodiments, personal data may include any data which relateto a living individual who can be identified: (1) from the data; or (2)from the data in combination with other information which is in thepossession of, or is likely to come into the possession of a particularentity. In particular embodiments, a particular entity may collect,store, process, and/or transfer personal data for one or more customers,one or more employees, etc.

In various embodiments, the system is configured to use one or more datamodels of the one or more data assets (e.g., data systems) to analyzeone or more data elements associated with those assets to determinewhether the one or more data elements include one or more data elementsthat include personal data and are subject to transfer. In particularembodiments, the transfer may include, for example: (1) an internaltransfer (e.g., a transfer from a first data asset associated with theentity to a second data asset associated with the entity); (2) anexternal transfer (e.g., a transfer from a data asset associated withthe entity to a second data asset associated with a second entity);and/or (3) a collective transfer (e.g., a transfer to a data assetassociated with the entity from an external data asset associated with asecond entity).

Next, at Step 3630, the system is configured to define a plurality ofphysical locations and identify, for each of the one or more datasystems, a particular physical location of the plurality of physicallocations. In some embodiments, the system is configured to define theplurality of physical locations based at least in part on input from auser. The system may, for example, define each of the plurality ofphysical locations based at least in part on one or more geographicboundaries. These one or more geographic boundaries may include, forexample: (1) one or more countries; (2) one or more continents; (3) oneor more jurisdictions (e.g., such as one or more legal jurisdictions);(4) one or more territories; (5) one or more counties; (6) one or morecities; (7) one or more treaty members (e.g., such as members of atrade, defense, or other treaty); and/or (8) any other suitablegeographically distinct physical locations.

The system may then be configured to identify, for each of the one ormore data systems identified at Step 3610, an associated physicallocation. For example, the system may be configured to determine inwhich of the one or more defined plurality of physical locations eachparticular data system is physically located. In particular embodiments,the system is configured to determine the physical location based atleast in part on one or more data attributes of a particular data asset(e.g., data system) using one or more data modeling techniques (e.g.,using one or more suitable data modeling techniques described herein).In some embodiments, the system may be configured to determine thephysical location of each data asset based at least in part on anexisting data model that includes the data asset. In still otherembodiments, the system may be configured to determine the physicallocation based at least in part on an IP address and/or domain of thedata asset (e.g., in the case of a computer server or other computingdevice) or any other identifying feature of a particular data asset.

Returning to Step 3640, the system is configured to analyze theidentified one or more data elements to determine one or more datatransfers between one or more data systems in different particularphysical locations. The system may, for example, analyze a data modelbased on each particular data asset to identify one or more datatransfers between and/or among the one or more data assets (e.g., datasystems). For example, as may be understood from FIG. 4 , a particularasset (e.g., storage asset) may receive data, for example, from a datasubject, a collection asset, or other suitable source (e.g., dataasset). The particular asset may further, in some embodiments, transferdata to a transfer asset (e.g., an asset to which the particular assettransfers data). The system may be configured to identify such datatransfers between and/or among one or more data assets for the purposeof generating a visual representation of such data transfers.

Continuing to Step 3650, the system is configured to determine one ormore regulations that relate to (e.g., apply to) the one or more datatransfers. As may understood in light of this disclosure, one or moreregulations (e.g., industry regulations, legal regulations, etc.) maygovern the transfer of personal data (e.g., between one or morejurisdictions, physical locations, and the like). In particular, the oneor more regulations may impose one or more minimum standards on thehandling of the transfer of such personal data in the interest ofprotecting the privacy of one or more data subjects or other individualswith whom the personal data is associated. In particular instances, itmay be inevitable (e.g., as a result of the sharing of customer data,the centralization of IT services, etc.) that a particular entity orcompany (e.g., a particular entity whose business activities span aplurality of jurisdictions or locations) will undertake one or more datatransfers that may triggers the one or more regulations.

In particular embodiments, the one or more regulations described abovemay include one or more transfer restrictions. In various embodiments,the one or more transfer restrictions may restrict transfer from a firstlocation (e.g., jurisdiction) to a second location (e.g., jurisdiction)absent an adequate level of privacy protection. A particular exemplarytransfer restriction may, for example, require data transferred from afirst location to a second location to be subject to the same level ofprivacy protection at the second location that the data enjoys in thefirst location. For example, the first location may, for example, placeany suitable limit on the collection and storage of personal data (e.g.,one or more time limits, one or more encryption requirements, etc.). Inparticular embodiments, the one or more regulations may include atransfer restriction that prohibits transfer of personal data from thefirst location to a second location unless the second location placeslimits on the collection and storage of personal data that are at leastas stringent as the first location.

In various embodiments, the system may, for example: (1) analyze one ormore first storage restrictions on personal data stored in a first dataasset; (2) analyze one or more second storage restrictions on personaldata stored in a second data asset to which the first data assettransfers personal data; and (3) compare the one or more first storagerestrictions with the one or more second storage restrictions. Thesystem may then, for example, flag a transfer of data from the firstdata asset to the second data asset based at least in part on thecomparison. For example, in response to determining that the one or moresecond restrictions are less stringent than the one or more firstrestrictions, the system may flag the transfer as risky or noncompliant.In another example, in response to determining that the one or moresecond restrictions are at least as stringent as the one or more firstrestrictions, the system may flag (e.g., automatically flag) thetransfer as acceptable or compliant.

In particular embodiments, the system may be configured to substantiallyautomatically determine that a transfer to a particular location isadequate. The system may, for example, store a listing (e.g., in memory)of one or more locations (e.g., countries) deemed automatically adequateas destinations of transferred personal data. In such embodiments, theone or more regulations may include a regulation that any location onthe ‘safe list’ provides adequate privacy protection for personal data.The system may then substantially automatically determine that atransfer of data that includes a ‘safe list’ location as a targetdestination in a transfer would automatically meet an adequacy standardfor data transfer. In a particular example, the one or more locations onthe ‘safe list’ may include one or more countries (e.g., Argentina,Canada, Israel, Switzerland, Uruguay, Jersey, Guernsey, the Isle of Man,etc.).

In various other embodiments, the one or more regulations may include aregulation that a transfer of personal data to a location that is partof a safe harbor is acceptable. In various embodiments, a safe harbormay include a commitment to adhere to a set of safe harbor principlesrelated to data protection. In a particular example, a United Statescompany wishing to identify as a safe harbor entity may be required toself-certify to the U.S. Department of Commerce that it adheres to theSafe Harbor principles and to make a public declaration of theadherence.

In particular other embodiments, the system may identify a particularprivacy shield arrangement between a first and second location in orderto determine an adequacy of a transfer of data from the first locationto the second location. In particular, a privacy shield arrangement mayfacilitate monitoring of an entity's compliance with one or morecommitments and enforcement of those commitments under the privacyshield. In particular, an entity entering a privacy shield arrangementmay, for example: (1) be obligated to publicly commit to robustprotection of any personal data that it handles; (2) be required toestablish a clear set of safeguards and transparency mechanisms on whocan access the personal data it handles; and/or (3) be required toestablish a redress right to address complaints about improper access tothe personal data.

In a particular example of a privacy shield, a privacy shield betweenthe United States and Europe may involve, for example: (1) establishmentof responsibility by the U.S. Department of Commerce to monitor anentity's compliance (e.g., a company's compliance) with its commitmentsunder the privacy shield; and (2) establishment of responsibility of theFederal Trade Commission having enforcement authority over thecommitments. In a further example, the U.S. Department of Commerce maydesignate an ombudsman to hear complaints from Europeans regarding U.S.surveillance that affects personal data of Europeans.

In some embodiments, the one or more regulations may include aregulation that allows data transfer to a country or entity thatparticipates in a safe harbor and/or privacy shield as discussed herein.The system may, for example, be configured to automatically identify atransfer that is subject to a privacy shield and/or safe harbor as ‘lowrisk.’

In some embodiments, the one or more regulations may include aregulation that a location that is not deemed automatically adequate asa data transfer target (e.g., a location to which data is beingtransferred) may be deemed adequate by entering one or more contracts(e.g., standard clauses) with an entity that is the source of thetransferred data. For example, the system may automatically determinethat a particular data transfer is adequate by identifying a contractthat exists between a first entity and a second entity, where the firstentity is transferring data from a first asset to a second assetassociated with the second entity. In various embodiments, the one ormore data elements that make up a data model (e.g., for the first dataasset) may indicate the existence of any contracts that the first entityhas executed related to the transfer of data with one or more otherentities. In various embodiments, the system is configured to analyzethe one or more contracts to determine whether the one or more contractsapply to a particular data transfer of the one or more transfersidentified at Step 3640.

In particular embodiments, the one or more contracts may include one ormore third party beneficiary rights to the one or more data subjectswhose personal data is subject to transfer. In such embodiments, suchcontracts may, for example, be enforced by an exporting entity (e.g.,the entity that is transferring the data) as well as the data subjectthemselves.

In particular embodiments, a further method of legitimizing a transferof data between one or more data assets may include implementing one ormore binding corporate rules. In particular embodiments, the one or morebinding corporate rules may be approved by a regulating authority. Insuch embodiments, the one or more regulations referred to in step 3650may include one or more regulations related to the existence of one ormore binding corporate rules (e.g., that have been approved by aregulating authority).

In various embodiments, the one or more binding corporate rules mayinclude a scheme that involves an entity (e.g., corporate group) settingup an internal suite of documents that set out how the entity intends toprovide adequate safeguards to individuals whose personal data is beingtransferred to a second location (e.g., country). In particularembodiments, the one or more binding corporate rules may include one ormore safeguards that are no less than those required by the location inwhich the personal data is originally stored.

At Step 3660, the system continues by generating a visual representationof the one or more data transfers based at least in part on the one ormore regulations. The system may, for example, generate a visualrepresentation of a map that includes the plurality of physicallocations described above. The system may then indicate, on the visualrepresentation, a location of each of the one or more data systems(e.g., using a suitable marker or indicia). In particular embodiments,the system may color code one or more of the plurality of physicallocations based on, for example, an existence of a privacy shield, aprevailing legal requirement for a particular jurisdiction, etc.

In various embodiments, the system may be configured to generate, on themap, a visual representation of a data transfer between at least a firstdata asset and a second data asset (e.g., where the first and seconddata asset are in two different physical locations). For example, thesystem may generate a linear representation of the transfer, or othersuitable representation. In particular embodiments, they system isconfigured to color code the visual representation of the transfer basedat least in part on the physical locations, one or more regulations,etc. In still other embodiments, the system is configured to color codethe visual representation of the transfer based at least in part on theone or more regulations that the system has determined apply to thetransfer (e.g., one or more binding corporate rules, privacy shield,etc.). This may, for example, indicate a legal basis of each particularidentified data transfer.

In various embodiments, the system may be configured to substantiallyautomatically flag a particular transfer of data as problematic (e.g.,because the transfer does not comply with an applicable regulation). Forexample, a particular regulation may require data transfers from a firstasset to a second asset to be encrypted. The system may determine, basedat least in part on the one or more data elements, that the transfer isnot encrypted. In response, the system may flag the transfer as Highrisk (e.g., using a particular color such as red). In various otherembodiments, the system may be configured to determine a risk level of aparticular transfer based at least in part on the physical location ofeach of the data assets, the one or more regulations, the type of databeing transferred (e.g., whether the data contains personal data), etc.

In particular embodiments, the visual representation may be used by aparticular entity to demonstrate compliance with respect to one or moreregulations related to the transfer of personal data. In suchembodiments, the visual representation may serve as a report thatindicates the legal basis of any transfer performed by the entity (e.g.,and further serve as documentation of the entity's compliance with oneor more legal regulations).

Risk Identification for Cross-Border Data Transfers

In various embodiments, the Cross-Border Visualization Generation Systemmay identify one or more risk associated with a cross-border datatransfer. In various embodiments, a data transfer record may be createdfor each transfer of data between a first asset in a first location anda second asset in a second location where the transfer record may alsoinclude information regarding the type of data being transferred, a timeof the data transfer, an amount of data being transferred, etc. Thesystem may apply data transfer rules to each data transfer record. Thedata transfer rules may be configurable to support different privacyframeworks (e.g., a particular data subject type is being transferredfrom a first asset in the European Union to a second asset outside ofthe European Union) and organizational frameworks (e.g., to support thedifferent locations and types of data assets within an organization).The applied data transfer rules may be automatically configured by thesystem (e.g., when an update is applied to privacy rules in a country orregion) or manually adjusted by the particular organization (e.g., by aprivacy officer of the organization). The data transfer rules to beapplied may vary based on the data being transferred. For example, ifthe data being transferred includes personal data, then particular datatransfer rules may be applied (e.g., encryption level requirements,storage time limitations, access restrictions, etc.).

In particular embodiments, the system may perform a data transferassessment on each data transfer record based on the data transfer rulesto be applied to each data transfer record. The data transfer assessmentperformed by the system may identify risks associated with the datatransfer record, and in some embodiments, a risk score may be calculatedfor the data transfer. For example, a data transfer that containssensitive data that includes a customer credit card, has a sourcelocation in one continent (e.g., at a merchant), and has a destinationlocation in a different continent (e.g., in a database), may have a highrisk score because of the transfer of data between two separatecontinents and the sensitivity of the data being transferred.

The risk score may be calculated in any suitable way, and may includerisk factors such as a source location of the data transfer, adestination location of the data transfer, the type of data beingtransferred, a time of the data transfer, an amount of data beingtransferred, etc. Additionally, the system may apply weighting factors(e.g., custom weighting factors or automatically determined ones) to therisk factors. Further, in some implementation, the system can include athreshold risk score where a data transfer may be terminated (e.g.,automatically) if the data transfer risk score indicates a higher riskthan the threshold risk score (e.g., the data transfer risk score beinghigher than the threshold risk score). When the data transfer risk scoreindicates a lower risk than the threshold risk score, then the systemmay process the data transfer. In some implementations, if one or moreof the risk factors indicate a heightened risk for the data transfer,then the system can notify an individual associated with the particularorganization. For example, the individual associated with the particularorganization may enable the data transfer to process, flag the datatransfer for further evaluation (e.g., send the data transferinformation to another individual for input), or terminate the datatransfer, among other actions.

The system may process the data transfer after evaluating the datatransfer assessment and/or the risk score for the data transfer.Additionally, in some implementations, the system may initiate the datatransfer via a secure terminal or secure link between a computer systemof the source location and a computer system of the destination locationwhere the system to prevent interception of the data or unwarrantedaccess to the additional information.

Cross-Border Visualization Generation User Experience

FIGS. 37-38 depict exemplary screen displays that a user may view whenreviewing a cross-border visualization generated by the system asdescribed above. As shown in FIG. 37 , the system may be configured togenerate a visual representation of an asset map (e.g., a data assetmap, data system map, etc.). As may be understood from this Figure, thesystem may be configured to generate a map that indicates a location ofone or more data assets for a particular entity. In the embodiment shownin this figure, locations that contain a data asset are indicated bycircular indicia that contain the number of assets present at thatlocation. In the embodiment shown in this figure, the locations arebroken down by country. In particular embodiments, the asset map maydistinguish between internal assets (e.g., first party servers, etc.)and external/third party assets (e.g., third party owned servers thatthe entity utilizes for data storage, transfer, etc.).

In some embodiments, the system is configured to indicate, via thevisual representation, whether one or more assets have an unknownlocation (e.g., because the data model described above may be incompletewith regard to the location). In such embodiments, the system may beconfigured to: (1) identify the asset with the unknown location; (2) useone or more data mapping techniques described herein to determine thelocation (e.g., pinging the asset); and (3) update a data modelassociated with the asset to include the location.

As shown in FIG. 38 , the system may be further configured to indicate,via a suitable line or other visual, a transfer of data between a firstasset in a first location and a second asset in a second location. Asmay be understood from this figure, the transfer indicated by the linehas a “High” risk level, contains sensitive data that includes acustomer credit card, has a source location of Spain (e.g., at amerchant), and has a destination location of Brazil (e.g., in adatabase). In various other embodiments, the system may generate avisual representation that includes a plurality of transfers between aplurality of asset locations.

Adaptive Execution on a Data Model

In various embodiments, a Data Model Adaptive Execution System may beconfigured to take one or more suitable actions to remediate anidentified risk trigger in view of one or more regulations (e.g., one ormore legal regulations, one or more binding corporate rules, etc.). Forexample, in order to ensure compliance with one or more legal orindustry standards related to the collection and/or storage of privateinformation (e.g., personal data), an entity may be required to modifyone or more aspects of a way in which the entity collects, stores,and/or otherwise processes personal data (e.g., in response to a changein a legal or other requirement). In order to identify whether aparticular change or other risk trigger requires remediation, the systemmay be configured to assess a relevance of the risk posed by thepotential risk trigger and identify one or more processing activities ordata assets that may be affected by the risk.

Certain functionality of a Data Model Adaptive Execution System may beimplemented via an Adaptive Execution on a Data Model Module 3900. Aparticular embodiment of the Adaptive Execution on a Data Model Module3900 is shown in FIG. 39 . When executing the Adaptive Execution on aData Model Module 3900, the system may be configured, at Step 3910, toidentify and/or detect one or more potential risk triggers. Inparticular embodiments, the system is configured to identify one or morepotential risk triggers in response to receiving a notification of asecurity breach (e.g., data breach) of one or more data assets (e.g.,one or more data assets utilized by a particular organization). Forexample, in response to receiving an indication that Salesforce (e.g., acustomer relationship management platform) has had a data breach, thesystem may identify one or more potential risk triggers in the form ofany data that the system receives from, or processes via Salesforce.

In still other embodiments, the system is configured to identify one ormore potential risk triggers in response to determining (e.g., receivingan input or indication) that one or more legal or industry requirementsthat relate to the collection, storage, and/or processing of personaldata have changed. For example, a particular legal regulation related toan amount of time that personal data can be stored, an encryption levelrequired to be applied to personal data, etc. may change. As anotherexample, a safe harbor arrangement (e.g., such as the safe harborarrangement discussed above) may be determined to be inadequatejustification for a transfer of data between a first and secondlocation. In this example, the system may be configured to receive anindication that ‘safe harbor’ is no longer an adequate justification fordata transfer from a first asset in a first location to a second assetin a second location.

Continuing to Step 3920, the system is configured to assess and analyzethe one or more potential risk triggers to determine a relevance of arisk posed by the one or more potential risk triggers. The system may,for example, determine whether the one or more potential risk triggersare related to one or more data assets (e.g., one or more data elementsof one or more data assets) and/or processing activities associated witha particular entity. When analyzing the one or more potential risktriggers to determine a relevance of a risk posed by the one or morepotential risk triggers, the system may be configured to utilize (e.g.,use) a formula to determine a risk level of the identified one or morepotential risk triggers. The system may, for example, determine the risklevel based at least in part on: (1) an amount of personal data affectedby the one or more potential risk triggers; (2) a type of personal dataaffected by the one or more potential risk triggers; (3) a number ofdata assets affected by the one or more potential risk triggers; and/or(4) any other suitable factor.

For example, in response to identifying a data breach in Salesforce, thesystem may, for example: (1) determine whether one or more systemsassociated with the entity utilize Salesforce; and (2) assess the one ormore systems utilized by Salesforce to evaluate a risk posed by the databreach. The system may, for example, determine that the entity utilizesSalesforce in order to store customer data such as name, address,contact information, etc. In this example, the system may determine thatthe Salesforce data breach poses a high risk because the data breach mayhave resulted in a breach of personal data of the entity's customers(e.g., data subjects).

In still another example, in response to determining that safe harbor isno longer a valid justification for a data transfer between twolocations, the system may be configured to: (1) determine whether one ormore data transfers involving one or more data assets associated withthe particular entity are currently justified via a safe harborarrangement; and (2) in response to determining that the one or moredata transfers are currently justified via a safe harbor arrangement,assessing a risk of the one or more transfers in view of the determinedinadequacy of safe harbor as a data transfer justification. Inparticular embodiments, the system may identify one or more supplementaljustifications and determine that the determined inadequacy of safeharbor poses a low risk. In other embodiments, the system may beconfigured to determine that the determined inadequacy of safe harborposes a high risk (e.g., because the system is currently performing oneor more data transfers that may be in violation of one or more legal,internal, or industry regulations related to data transfer).

Returning to Step 3930, the system is configured to use one or more datamodeling techniques to identify one or more processing activities and/ordata assets that may be affected by the risk. As discussed above, thesystem may utilize a particular data model that maps and/or indexes dataassociated with a particular data asset. The data model may, forexample, define one or more data transfers, one or more types of data,etc. that are associated with a particular data asset and/or processingactivity. In some embodiments, the system is configured to use the datamodel to identify one or more data assets and/or processing activitiesthat may be affected by the risk assessed at Step 3920. In variousembodiments, the system is configured to identify, using any suitabledata modeling technique described herein, one or more pieces of personaldata that the system is configured to collect, store, or otherwiseprocess that may be affected by the one or more potential risk triggers.

Next, at Step 3940, the system is configured to determine, based atleast in part on the identified one or more processing activities and/ordata assets and the relevance of the risk, whether to take one or moreactions in response to the one or more potential risk triggers. Inparticular embodiments, the system may, for example: (1) determine totake one or more actions in response to determining that a calculatedrisk level is above a threshold risk level; (2) determine to take theone or more actions in response to determining that the one or morepotential risk triggers may place the entity in violation of one or moreregulations (e.g., legal and/or industry regulations); etc.

In some embodiments, the system may determine whether to take one ormore actions based at least in part on input from one or moreindividuals associated with the entity. The one or more individuals mayinclude, for example, one or more privacy officers, one or more legalrepresentatives, etc. In particular embodiments, the system isconfigured to receive input from the one or more individuals, anddetermine whether to take one or more actions in response to the input.

Continuing to Step 3950, the system is configured to take one or moresuitable actions to remediate the risk in response to identifying and/ordetecting the one or more potential risk triggers.

In particular embodiments, the one or more actions may include, forexample: (1) adjusting one or more data attributes of a particular dataasset (e.g., an encryption level of data stored by the data asset, oneor more access permissions of data stored by the particular data asset,a source of data stored by the particular data asset, an amount of timethe data is stored by a particular asset, etc.); (2) generating a reportindicating the risk level and the identified one or more risk triggers;(3) providing the report to one or more individuals (e.g., a privacyofficer or other individual); and/or (4) taking any other suitableaction, which may, for example, be related to the identified one or morepotential risk triggers.

Automatic Risk Remediation Process

In various embodiments, a system may be configured to substantiallyautomatically determine whether to take one or more actions in responseto one or more identified risk triggers as discussed above in thecontext of the Adaptive Execution on a Data Model Module 3900. Inparticular embodiments, the system is configured to substantiallyautomatically perform one or more steps related to the analysis of andresponse to the one or more potential risk triggers discussed above. Forexample, the system may substantially automatically determine arelevance of a risk posed by (e.g., a risk level) the one or morepotential risk triggers based at least in part on one or morepreviously-determined responses to similar risk triggers. This mayinclude, for example, one or more previously determined responses forthe particular entity that has identified the current risk trigger, oneor more similarly situated entities, or any other suitable entity orpotential trigger.

In particular embodiments, the system may, for example, when determiningwhether to take one or more actions in response to the one or morepotential risk triggers (e.g., as discussed above with respect to Step3940 of the Adaptive Execution on a Data Model Module): (1) compare thepotential risk trigger to one or more previous risks triggersexperienced by the particular entity at a previous time; (2) identify asimilar previous risk trigger (e.g., one or more previous risk triggersrelated to a similar change in regulation, breach of data, type of issueidentified, etc.); (3) determine the relevance of the current risktrigger based at least in part on a determined relevance of the previousrisk trigger; and (4) determine whether to take one or more actions tothe current risk trigger based at least in part on one or moredetermined actions to take in response to the previous, similar risktrigger.

Similarly, in particular embodiments, the system may be configured tosubstantially automatically determine one or more actions to take inresponse to a current potential risk trigger based on one or moreactions taken by one or more similarly situated entities to one or moreprevious, similar risk triggers. For example, the system may beconfigured to: (1) compare the potential risk trigger to one or moreprevious risk triggers experienced by one or more similarly situatedentities at a previous time; (2) identify a similar previous risktrigger (e.g., one or more previous risk triggers related to a similarchange in regulation, breach of data, and/or type of issue identified,etc. from the one or more previous risk triggers experienced by the oneor more similarly-situated entities at the previous time; (3) determinethe relevance of the current risk trigger based at least in part on adetermined relevance of the previous risk trigger (e.g., a relevancedetermined by the one or more similarly situated entities); and (4)determine one or more actions to take in response to the current risktrigger based at least in part on one or more previously determinedactions to take in response to the previous, similar risk trigger (e.g.,one or more determined actions by the one or more similarly situatedentities at the previous time).

In various embodiments, the one or more similarly-situated entities mayinclude, for example: (1) one or more other entities in a geographiclocation similar to a geographic location of the entity that hasidentified the one or more potential risk triggers (e.g., a similarcountry, jurisdiction, physical location, etc.); (2) one or more otherentities in a similar industry (e.g., banking, manufacturing,electronics, etc.); (3); one or more entities of a similar size (e.g.,market capitalization, number of employees, etc.); (4) one or moreentities that are governed by one or more similar regulations (e.g.,such as any suitable regulation discussed herein); and/or (5) any othersuitably similarly situated entity.

In various embodiments, the system is configured to use one or moremachine learning techniques to analyze one or more risk levels assignedto previously identified risk triggers, determine a suitable response tosimilar, currently-identified risk triggers based on previouslydetermined responses, etc.

In particular embodiments, the system may, for example, be configuredto: (1) receive risk remediation data for a plurality of identified risktriggers from a plurality of different entities; (2) analyze the riskremediation data to determine a pattern in assigned risk levels anddetermined response to particular risk triggers; and (3) develop a modelbased on the risk remediation data for use in facilitating an automaticassessment of and/or response to future identified risk triggers.

In a particular example of a reactive system for automaticallydetermining a suitable action to take in response to an identified risktrigger, the system may take one or more suitable actions in response toidentifying a data beach in Salesforce (e.g., as discussed above). Inparticular embodiments, the system may, for example: (1) substantiallyautomatically identify one or more actions taken by the system inresponse to a similar data breach of one or more different vendors; and(2) determine a suitable action to take in response to the data breachbased on the one or more actions taken in response to the similar databreach. The similar data breach may include, for example, a breach indata of a similar type, or any other similar breach.

In another example, the system may be configured to identify one or moresimilarly situated entities that have experienced a data breach viaSalesforce or other similar vendor. The system, may, for example, beconfigured to determine a suitable action to take based at least in parton an action taken by such a similar entity to a similar data breach. Instill another example, the system may be configured, based on one ormore previous determinations related to a data breach by a vendor (e.g.,such as by Salesforce) to take no action in response to the identifiedrisk trigger (e.g., because the identified risk may pose no or minimaldanger).

Systems and Methods for Automatically Remediating Identified Risks

A data model generation and population system, according to particularembodiments, is configured to generate a data model (e.g., one or moredata models) that maps one or more relationships between and/or among aplurality of data assets utilized by a corporation or other entity(e.g., individual, organization, etc.) in the context, for example, ofone or more business processes. In particular embodiments, each of theplurality of data assets (e.g., data systems) may include, for example,any entity that collects, processes, contains, and/or transfers data(e.g., such as a software application, “internet of things” computerizeddevice, database, web site, data-center, server, etc.). For example, afirst data asset may include any software or device (e.g., server orservers) utilized by a particular entity for such data collection,processing, transfer, storage, etc.

In particular embodiments, a system may be configured to generate andmaintain one or more disaster recovery plans for particular data assetsbased on one or more relationships between/among one or more data assetsoperated and/or utilized by a particular entity.

In various embodiments, a system may be configured to substantiallyautomatically determine whether to take one or more actions in responseto one or more identified risk triggers. For example, an identified risktrigger include any suitable risk trigger such as that a data asset foran organization is hosted in only one particular location therebyincreasing the scope of risk if the location were infiltrated (e.g., viacybercrime). In particular embodiments, the system is configured tosubstantially automatically perform one or more steps related to theanalysis of and response to the one or more potential risk triggersdiscussed above. For example, the system may substantially automaticallydetermine a relevance of a risk posed by (e.g., a risk level) the one ormore potential risk triggers based at least in part on one or morepreviously-determined responses to similar risk triggers. This mayinclude, for example, one or more previously determined responses forthe particular entity that has identified the current risk trigger, oneor more similarly situated entities, or any other suitable entity orpotential trigger.

In particular embodiments, the system may, for example, be configuredto: (1) receive risk remediation data for a plurality of identified risktriggers from a plurality of different entities; (2) analyze the riskremediation data to determine a pattern in assigned risk levels anddetermined response to particular risk triggers; and (3) develop a modelbased on the risk remediation data for use in facilitating an automaticassessment of and/or response to future identified risk triggers.

In some embodiments, in response to a change or update is made to one ormore processing activities and/or data assets (e.g., a databaseassociated with a particular organization), the system may use datamodeling techniques to update the risk remediation data for use infacilitating an automatic assessment of and/or response to futureidentified risk triggers. For example, the system may be configured touse a data map and/or data model described herein to, for example: (1)particular systems that may require some remedial action in response toan identified breach/incident for one or more related systems; (2)automatically generate a notification to an individual to update adisaster recovery plan for those systems; and/or (3) automaticallygenerate a disaster recovery plan that includes one or more actions inresponse to identifying an incident in one or more related systemsidentified using the data mapping techniques described herein. Invarious embodiments, in response to modification of a privacy campaign,processing activity, etc. of the particular organization (e.g., add,remove, or update particular information), the system may update therisk remediation data for use in facilitating an automatic assessment ofand/or response to future identified risk triggers. For example, thesystem may be configured to (1) identify one or more changes to one ormore relationships between/among particular data assets in response to achange in one or more business processes; and (2) modify (e.g., and/orgenerate a notification to modify) one or more disaster recovery plansfor any affected data assets.

In particular embodiments, the system may, for example, be configuredto: (1) access risk remediation data for an entity that identifies oneor more suitable actions to remediate a risk in response to identifyingone or more data assets of the entity that may be affected by one ormore potential risk triggers; (2) receive an indication of an update tothe one or more data assets; (3) identify one or more potential updatedrisk triggers for an entity; (4) assess and analyze the one or morepotential updated risk triggers to determine a relevance of a risk posedto the entity by the one or more potential updated risk triggers; (5)use one or more data modeling techniques to identify one or more dataassets associated with the entity that may be affected by the risk; and(6) update the risk remediation data to include the one or more actionsto remediate the risk in response to identifying the one or morepotential updated risk triggers.

Webform Crawling to Map Processing Activities in a Data Model

In particular embodiments, a data mapping system (e.g., such as anysuitable data mapping and/or modeling system described herein) may beconfigured to generate a data model that maps one or more relationshipsbetween and/or among a plurality of data assets utilized by acorporation or other entity (e.g., individual, organization, etc.) inthe context, for example, of one or more business processes and/orprocessing activities. In various embodiments, when generating the datamodel, the system may identify one or more webforms utilized by thesystem in the collection and processing of personal data and determineone or more particular data assets and/or processing activities thatutilize such data. Although in the course of this description, thesystem is described as crawling (e.g., and/or scanning) one or morewebforms, it should be understood that other embodiments may be utilizedto scan, crawl or analyze any suitable electronic form in order to mapany data input via the electronic form in any suitable manner.

In particular embodiments, the system may be configured to use one ormore website scanning tools to, for example: (1) identify a webform(e.g., on a website associated with a particular entity ororganization); (2) robotically complete the webform; (3) and analyze thecompleted webform to determine one or more particular processingactivities, and/or business processes, etc. that use one or more piecesof data submitted via the webform.

As may be understood in light of this disclosure, one or more legaland/or industry regulations may require an entity to, for example,maintain a record of one or more processing activities undertaken by theentity that includes: (1) a name and contact details of a controllerresponsible for the processing activity; (2) a purpose of theprocessing; (3) a description of one or more categories of data subjectsand/or of one or more categories of personal data collected as part ofthe processing activity; (4) one or more categories of recipients towhom the personal data may be disclosed, including recipients in one ormore second countries or other locations; (5) one or more transfers ofthe personal data to a second country or an international organization;(6) a time limit for erasure of the personal data, if applicable; (7) anidentification of one or more security measures taken in the collectionand/or storage of the personal data; and/or (8) any other suitableinformation.

As may be further understood in light of this disclosure, a particularorganization may undertake a plurality of different privacy campaigns,processing activities, etc. that involve the collection and storage ofpersonal data. In some embodiments, each of the plurality of differentprocessing activities may collect redundant data (e.g., may collect thesame personal data for a particular individual more than once), and maystore data and/or redundant data in one or more particular locations(e.g., on one or more different servers, in one or more differentdatabases, etc.). Additionally, one or more sub-organizations (e.g.,subgroups) of an organization or entity may initiate a processingactivity that involves the collection of personal data without vettingthe new processing activity with a privacy compliance officer or otherindividual within the company tasked with ensuring compliance with oneor more prevailing privacy regulations. In this way, a particularorganization may collect and store personal data in a plurality ofdifferent locations which may include one or more known and/or unknownlocations, or may collect personal data for a purpose that is notimmediately apparent (e.g., using one or more webforms). As such, it maybe desirable for an entity to implement a system that is configured toscan one or more webforms that collect personal data to identify whichparticular processing activity (e.g., or processing activities) thatpersonal data is utilized in the context of.

Various processes are performed by the Data Access Webform CrawlingSystem and may be implemented by a Webform Crawling Module 4300.Referring to FIG. 43 , in particular embodiments, the system, whenexecuting the Webform Crawling Module 4300, is configured to: (1)identify a webform used to collect one or more pieces of personal data;(2) robotically complete the identified webform; (3) analyze thecompleted webform to determine one or more processing activities thatutilize the one or more pieces of personal data collected by thewebform; (4) identify a first data asset in the data model that isassociated with the one or more processing activities; (5) modify a datainventory for the first data asset in the data model to include dataassociated with the webform; and (6) modify the data model to includethe modified data inventory for the first data asset.

When executing the Webform Crawling Module 4300, the system begins, atStep 4310, by identifying a webform used to collect one or more piecesof personal data. The system may use one or more website scanning toolsto identify the webform. The webform may be a website associated with aparticular entity or organization. For example, the webform may be a“Contact Us” form that is on the particular organization's website orany other type of webform associated with the particular organization.At Step 4320, the system is configured to robotically complete theidentified webform. The identified webform may be completed by using avirtual profile that emulates a user profile, and the virtual profilemay include an e-mail address. The system may monitor the e-mail accountassociated with the e-mail address for a confirmation e-mail related tothe completion of the identified webform where the system may receiveand interact with the confirmation e-mail. Additionally, the system mayanalyze (e.g., scrape) the confirmation e-mail for the data associatedwith the webform. The data associated with the webform may identify oneor more processing activities and one or more pieces of personal datacollected by the webform.

Next, at Step 4330, the system is configured to analyze the completedwebform to determine one or more processing activities that utilize theone or more pieces of personal data collected by the webform. In someimplementations, the system may analyze one or more pieces of computercode associated with the webform to determine the one or more processingactivities that utilize the one or more pieces of personal datacollected by the webform. Further, the system may analyze the one ormore pieces of computer code to identify a storage location to which theone or more pieces of personal data collected by the webform are routed.At Step 4340, the system is configured to identify a first data asset inthe data model that is associated with the one or more processingactivities. In some implementations, the system may identify aprocessing activity based on the storage location of the identified oneor more pieces of personal data, and an asset may be associated with aparticular storage location.

Continuing to Step 4350, the system is configured to modify a datainventory for the first data asset in the data model to include dataassociated with the webform. The system may include an indication thatthe one or more processing activities operate with data included in thefirst data asset. Additionally, the system may indicate that the one ormore pieces of personal data are utilized by the identified one or moreprocessing activities.

At Step 4360, the system continues by modifying the data model toinclude the modified data inventory for the first data asset. In someimplementations, the system may include a mapping of the first dataasset to the one or more processing activities that utilize the one morepieces of personal data. The mapping may be based on the analysis of thecomputer code associated with the webform. Moreover, in someimplementations, the system may add the first data asset to athird-party data repository, and the first data asset may include anelectronic link to the webform. The third-party repository is furtherdiscussed below.

Central Consent Repository

In particular embodiments, any entity (e.g., organization, company,etc.) that collects, stores, processes, etc. personal data may requireone or more of: (1) consent from a data subject from whom the personaldata is collected and/or processed; and/or (2) a lawful basis for thecollection and/or processing of the personal data. In variousembodiments, the entity may be required to, for example, demonstratethat a data subject has freely given specific, informed, and unambiguousindication of the data subject's agreement to the processing of his orher personal data for one or more specific purposes (e.g., in the formof a statement or clear affirmative action). As such, in particularembodiments, an organization may be required to demonstrate a lawfulbasis for each piece of personal data that the organization hascollected, processed, and/or stored. In particular, each piece ofpersonal data that an organization or entity has a lawful basis tocollect and process may be tied to a particular processing activityundertaken by the organization or entity.

A particular organization may undertake a plurality of different privacycampaigns, processing activities, etc. that involve the collection andstorage of personal data. In some embodiments, each of the plurality ofdifferent processing activities may collect redundant data (e.g., maycollect the same personal data for a particular individual more thanonce), and may store data and/or redundant data in one or moreparticular locations (e.g., on one or more different servers, in one ormore different databases, etc.). In this way, because of the number ofprocessing activities that an organization may undertake, and the amountof data collected as part of those processing activities over time, oneor more data systems associated with an entity or organization may storeor continue to store data that is not associated with any particularprocessing activity (e.g., any particular current processing activity).Under various legal and industry standards related to the collection andstorage of personal data, such data may not have or may no longer have alegal basis for the organization or entity to continue to store thedata. As such, organizations and entities may require improved systemsand methods to maintain an inventory of data assets utilized to processand/or store personal data for which a data subject has provided consentfor such storage and/or processing.

In various embodiments, the system is configured to provide athird-party data repository system to facilitate the receipt andcentralized storage of personal data for each of a plurality ofrespective data subjects, as described herein. Additionally, thethird-party data repository system is configured to interface with acentralized consent receipt management system.

In various embodiments, the system may be configured to, for example:(1) identify a webform used to collect one or more pieces of personaldata, (2) determine a data asset of a plurality of data assets of theorganization where input data of the webform is transmitted, (3) add thedata asset to the third-party data repository with an electronic link tothe webform, (4) in response to a user submitting the webform, create aunique subject identifier to submit to the third-party data repositoryand the data asset along with the form data provided by the user in thewebform, (5) submit the unique subject identifier and the form dataprovided by the user in the webform to the third-party data repositoryand the data asset, and (6) digitally store the unique subjectidentifier and the form data provided by the user in the webform in thethird-party data repository and the data asset.

In some embodiments, the system may be further configured to, forexample: (1) receive a data subject access request from the user (e.g.,a data subject rights' request, a data subject deletion request, etc.),(2) access the third-party data repository to identify the uniquesubject identifier of the user, (3) determine which data assets of theplurality of data assets of the organization include the unique subjectidentifier, (4) access personal data of the user stored in each of thedata assets of the plurality of data assets of the organization thatinclude the unique subject identifier, and (5) take one or more actionsbased on the data subject access request (e.g., delete the accessedpersonal data for a data subject deletion request).

The system may, for example: (1) generate, for each of a plurality ofdata subjects, a respective unique subject identifier in response tosubmission, by each data subject, of a particular webform; (2) maintaina database of each respective unique subject identifier; and (3)electronically link each respective unique subject identifier to eachof: (A) a webform initially submitted by the user; and (B) one or moredata assets that utilize data received from the data subject via thewebform.

The Webform Crawling Data System may also implement a Data Asset andWebform Management Module 4400. Referring to FIG. 44 , in particularembodiments, the system, when executing the Data Asset and WebformManagement Module 4400, is configured for: (1) identifying a webformused to collect one or more pieces of personal data; (2) determining adata asset of a plurality of data assets of the organization where inputdata of the webform is transmitted; (3) adding the data asset to thethird-party data repository with an electronic link to the webform; (4)in response to a user submitting the webform, creating a unique subjectidentifier to submit to the third-party data repository and the dataasset along with form data provided by the user in the webform; (5)submitting the unique subject identifier and the form data provided bythe user in the webform to the third-party data repository and the dataasset; and (6) digitally storing the unique subject identifier and theform data provided by the user in the webform in the third-party datarepository and the data asset.

When executing the Data Asset and Webform Management Module 4400, thesystem begins, at Step 4410, by identifying a webform used to collectone or more pieces of personal data. In particular embodiments, thesystem may be configured to use one or more website scanning tools to,for example, identify a webform. The webform may be a website associatedwith a particular entity or organization. For example, the webform maybe a “Contact Us” form that is on the particular organization's websiteor any other type of webform associated with the particularorganization.

At Step 4420, the system is configured to determine a data asset of aplurality of data assets of the organization where input data of thewebform is transmitted. The system may perform the determination byidentifying where the input data of the webform is transmitted (e.g.,Salesforce). Continuing to Step 4430, the system is configured to addthe data asset to the third-party data repository with an electroniclink to the webform. The system may provide the third-party datarepository with a reference to the data asset, or in someimplementations, the system may provide the one or more pieces ofpersonal data that were transmitted to the one or more data assets tothe third-party repository. The system may associate the electronic linkto the webform with the identified data asset that includes the one ormore pieces of personal data.

Returning to Step 4440, the system is configured to create a uniquesubject identifier to submit to the third-party data repository and thedata asset along with form data provided by the user in the webform inresponse to a user submitting the webform. In response to a userinputting form data (e.g., name, address, credit card information, etc.)at the webform and submitting the webform, the system may, based on thelink to the webform, create a unique subject identifier to identify theuser. The unique subject identifier may be any type of numerical,alphabetical, or any other type of identifier to identify the user.

Continuing to Step 4450, the system is configured to submit the uniquesubject identifier and the form data provided by the user in the webformto the third-party data repository and the data asset. The system isconfigured to submit the unique subject identifier to the third-partydata repository and the data asset along with the form data. Further,the system may use the unique subject identifier of a user to access andupdate each of the data assets of the particular organization (i.e.,including the other data assets of the particular organization where theform data is not transmitted). For example, in response to a usersubmitting a data subject access request to delete personal data theparticular organization has stored of the user, the system may use theunique subject identifier of the user to access and retrieve the user'spersonal data stored in all of the data assets (e.g., Salesforce,Eloqua, Marketo, etc.) utilized by the particular organization. At Step4460, the system continues by digitally storing the unique subjectidentifier and the form data provided by the user in the webform in thethird-party data repository and the data asset.

Further, in some implementations, the system may be configured toreceive a data subject access request from the user. The data subjectaccess request may be one or more different types of data subject accessrequests, and may be, for example, a data subject deletion request or adata subject rights request. Upon the system receiving the data subjectaccess request, the system may be configured to access the third-partydata repository to identify the unique subject identifier of the user,determine which data assets of the plurality of data assets of theorganization include the unique subject identifier, and access personaldata of the user stored in each of the data assets of the plurality ofdata assets of the organization that include the unique subjectidentifier. Upon the data subject access request being a data subjectdeletion request, then the system may delete the accessed personal dataof the user stored in each of the data assets of the plurality of dataassets of the organization that include the unique subject identifier.When the data subject access request is a data subject rights request,the system may generate a data subject rights request report thatincludes the accessed personal data of the user stored in each of thedata assets of the plurality of data assets of the organization thatinclude the unique subject identifier. Further, the data subject rightsrequest report may be transmitted to the user. In some implementations,the system may transmit the data subject rights request report to theuser via a secure electronic link.

Webform Generation User Experience

FIG. 40 depicts an exemplary webform that a particular entity mayinclude on a website for completion by one or more customers or users ofthe website. As may be understood from FIG. 40 , the webform may collectpersonal data such as, for example: (1) first name; (2) last name; (3)organization name; (4) country of residence; (5) state; (6) phonenumber; (7) e-mail address; (8) website; and/or (9) any other suitablepersonal data. As may be further understood from this Figure, an entity(e.g., or a system controlled by the entity) may use the webform tocollect such personal data as part of one or more processing activities(e.g., e-mail marketing, online surveys, event marketing, etc.). Invarious embodiments, the system may be configured to scan a particularwebform to identify a particular processing activity for which theentity is collecting the personal data.

In various embodiments, the system may, for example: (1) roboticallyfill out the webform (e.g., using one or more virtual profiles); (2)analyze one or more pieces of computer code associated with the webform(e.g., javascript, HTML, etc.); and (3) map one or more businessprocesses that utilize the data collected via the webform based at leastin part on the analyzed one or more pieces of computer code. Inparticular embodiments, a particular entity that utilizes a webform tocollect personal data for use in a particular processing activity (e.g.,business process) may analyze one or more pieces of computer codeassociated with the webform to determine: (1) one or more systemsassociated with the entity to which data entered the webform is routed(e.g., one or more data assets that serve as a destination asset to dataentered via the webform); (2) a purpose for the collection of the dataentered via the webform (e.g., a processing activity that utilizes thedestination asset discussed above; (3) a type of data collected via thewebform; and/or (4) any other suitable information related to thecollection of data via the webform.

In particular embodiments, a system may be configured to transmit awebform completion confirmation e-mail to a user that completes thewebform. In various embodiments, the system may be configured to analyzethe e-mail or other message to identify one or more business processesthat utilize the data collected by the webform (e.g., byanalyzing/scraping one or more contents of the e-mail or other message).The system may then determine a purpose of the data collection and/or anassociated processing activity based at least in part on the analysis.

Scanning Electronic Correspondence to Facilitate Automatic Data SubjectAccess Request Submission

In various embodiments, any system described herein may be configuredfor: (1) analyzing electronic correspondence associated with a datasubject (e.g., the emails within one or more email in-boxes associatedwith the data subject, or a plurality of text messages); (2) based onthe analysis, identifying one or more entities (e.g., corporateentities) that that the data subject does not actively do business with(e.g., as evidenced by the fact that the data subject no longer opensemails from the entity, has set up a rule to automatically delete emailsreceived from the entity, has blocked texts from the entity, etc.); (3)in response to identifying the entity as an entity that the data subjectno longer does business with, at least substantially automaticallygenerating a data subject access request and, optionally, automaticallysubmitting the data subject access request to the identified entity.

The system may, for example, be configured to determine whether the datasubject still uses one or more services from a particular e-mail sender(e.g., service provider) based at least in part on one more determinedinteractions of the data subject with one or more e-mails, or otherelectronic correspondence, from the service provider (e.g., whether thedata subject reads the e-mail, selects one or more links within thee-mail, deletes the e-mail without reading it, etc.). The system maythen substantially automatically generate and/or complete a data subjectaccess request on behalf of the data subject that includes a request tobe forgotten (e.g., a request for the entity to delete some or all ofthe data subject's personal data that the entity is processing).

For purposes of simplicity, various embodiments will now be described inwhich the system scans a plurality of emails associated with a datasubject in order to identify one or more entities that the data subjectno longer does business with. However, it should be understood that, inother embodiments, the same or similar techniques may be used inanalyzing other types of electronic or other correspondence to identifyentities that the data subject no longer does business with. Forexample, the system may analyze text messages, social media posts, scansof paper mail, or any other correspondence and/or other documentsassociated with the data subject to determine whether the data subjectdoes business with particular entities. In various embodiments, thesystem bases this determination on its analysis of multiple differenttypes of electronic correspondence between the data subject and one ormore entities (which may include one-way correspondence in which therecipient of a particular correspondence doesn't respond, or two-waycorrespondence, in which the recipient of the correspondence responds tothe correspondence).

In various embodiments, various functions performed by an E-mailScanning System may be implemented via an E-mail Scanning Module 4100.FIG. 41 depicts an E-mail Scanning Module 4100 according to a particularembodiment, which may be executed, for example, on any of the servers110, 120, 130, 160 shown in FIG. 1 , or on one or more remote computingdevices 150. When executing an exemplary E-mail Scanning Module 4100,the system begins, at Step 4110, by providing a software application forinstallation on a computing device. In particular embodiments, thesoftware application may be configured to integrate with an e-mailservice (e.g., gmail, yahoo, live, Microsoft Exchange, etc.) in order toprovide access to a data subject's e-mail (e.g., a data subject'se-mail). In particular embodiments, the software application may beembodied as a software plugin that interfaces with a particular softwareapplication (e.g., Microsoft Outlook) in order to provide access to thedata subject's e-mail to the systems. In other embodiments, the softwareapplication may be embodied as a browser plugin for use with a webbrowser to provide access to the data subject's web-based e-mailservice. In particular embodiments, the system is configured to providethe software application for installation on a data subject's computingdevice (e.g., mobile computing device, etc.). In such embodiments, thesoftware application may be embodied as a client-side softwareapplication that executes one or more of the processes described belowon a client computing device (e.g., such as the data subject's computingdevice on which the data subject accesses his or her e-mails).

In still other embodiments, the system is configured to provide thesoftware application for installation on one or more suitable servers(e.g., one or more suitable servers that host a particular e-mailservice). In particular embodiments, for example, the system isconfigured to: (1) receive authorization from a data subject to accesshis or her e-mails; and (2) use a software application installed on oneor more remote servers to perform one or more of the functions describedbelow. In such embodiments, the system may be configured to provide thesoftware application to the one or more remote servers. In particularother embodiments, the system may be at least partially integrated inone or more remote servers (e.g., via a direct server integration). Insuch embodiments, the system may be at least partially integrated withone or more remote e-mail servers (e.g., one or more remote servers thatstore and/or process a data subject's emails).

Returning to Step 4120, the system is configured to use the softwareapplication to scan and optionally index one or more data subjecte-mails, and then analyze information derived from the emails toidentify a subject entity (e.g., corporate or non-corporate entity) fromwhich each of the one or more data subject e-mails was received by adata subject. The system may, for example, be configured to scan and/orindex the data subject's emails to identify one or more subject entitiesas the sender of the emails. In particular embodiments, the one or moresubject entities may include one or more subject entities (e.g.,corporate entities) that would be required to respond to a data subjectaccess request, if received from the data subject. For example, the oneor more subject entities may include any subject company that collects,stores, or otherwise processes the data subject's personal data. Thesystem may, for example, be configured to identify particular e-mails ofthe data subject's indexed e-mails that were received from any suitableentity (e.g., Target, Home Depot, etc.). The system may, for example,scan an e-mail's subject field, body, sender, etc. to identify, forexample: (1) a name of the subject company; (2) an e-mail domainassociated with the subject company; and/or (3) any other suitableinformation which may identify the subject entity as the sender of thee-mail.

In some embodiments, the system may be configured to identify e-mailmessages from a subject entity based at least in part on an emailmailbox in which the messages are located in the data subject's e-mailaccount. For example, the data subject's e-mail account may alreadypre-sort incoming messages into one or more categories (e.g., which mayinclude, for example, a promotions category, a junk category, etc.). Insuch embodiments, the system may be configured to limit the one or moree-mails that the system scans and/or indexes to e-mails that have beenidentified as promotional in nature (or that have been placed into anyother pre-defined category, such as Spam) by the data subject's e-mailservice.

Continuing to Step 4130, the system is configured to use an algorithm todetermine whether the data subject actively does business with theentity. In particular embodiments, the system is configured to make thisdetermination based at least in part on (e.g., partially or entirelyon): (1) whether the data subject opens any of the one or more e-mailsreceived from the subject company; (2) how long the data subject spendsreviewing one or more of the e-mails that the data subject does openfrom the subject company; (3) whether the data subject deletes one ormore of the e-mails from the subject company without reading them; (4)what portion (e.g., percentage) of e-mails received from the subjectcompany the data subject opens; (5) whether the data subject selects oneor more links contained in one or more e-mails received from the subjectcompany; (6) how much time the data subject spends viewing a website towhich a link is provided in the one or more e-mails from the subjectcompany; (7) whether the data subject has set up a rule (e.g., asoftware-based rule) to auto-delete or block emails from the subjectcompany; (8) whether the data subject has set up a rule (e.g., asoftware-based rule) to redirect emails received from the subjectcompany to a specific folder or other location (e.g., a folderdesignated for commercial correspondence, or a folder designated forunwanted correspondence); (9) whether the data subject has submitted arequest to the particular entity for the particular entity not to sendemails to the data subject; (10) whether the data subject has submitteda request to the particular entity for the particular entity not to sendtext messages to the data subject; (11) whether the data subject hassubmitted a request to the particular entity for the particular entitynot to call the data subject; and/or (12) any other suitable informationrelated to the data subject's use of one or more services, or purchaseof goods, related to the one or more e-mails or other electroniccorrespondence received by the data subject from the subject company. Inparticular embodiments, the system is configured to automatically (e.g.,using one or more computer processors) determine the information of anyof the items listed above (e.g., whether the data subject has set up arule to redirect emails received from the subject company to a specificfolder) using any suitable technique.

As noted above, the system may, in addition, or alternatively, make thedetermination described above by analyzing electronic correspondenceother than emails, such as texts, social media postings, etc. thatinvolve the data subject and the entity. For example, the system maydetermine that the data subject no longer actively does business with aparticular entity if the data subject configures software (e.g.,messaging software on the data subject's smartphone) to block texts fromthe particular entity.

In various embodiments, the system is configured to utilize an algorithmthat takes into account one or more of the various factors discussedabove to determine whether the data subject still actively does businesswith the subject entity (e.g., and therefore would likely be interestedin continuing to receive e-mails from the subject company). In doing so,the system may assign any appropriate value to each of the factors indetermining whether to determine that the data subject no longer doesbusiness with the subject entity. Similarly, the system may allow thecalculation to be customized by allowing users to assign weightingfactors to each particular variable.

As a simple example, the system may use the following formula todetermine whether the data subject does business with a particularentity:Data Subject Disengagement Rating=(Emails Opened Value)+(Texts ReadValue)+(Emails Automatically Deleted Value)+(Texts Blocked Value)

In a particular example, the system is configured to determine that thedata subject no longer actively does business with the entity if theData Subject Disengagement Rating is above 80. In this example, thesystem may assign: (1) a value of 80 to the Emails Read Value if thedata subject opens fewer than 5% of emails received from the from theentity; (2) a value of 50 to the Emails Read Value if the data subjectopens between 5%-25% of emails received from the entity; and (3) a valueof 0 to the Emails Read Value if the data subject opens over 25% ofemails received from the from the entity. The system may assign similarvalues to the other variables based on the user's other email and textrelated activities. For example, the system may assign a value of 100 toText Blocked Value if the data subject has actively blocked (e.g., viasoftware instructions) texts from the entity, and a value of 0 to TextBlocked Value if the data subject has not actively blocked texts fromthe entity. Similarly, the system may assign a value of 100 to EmailsAutomatically Deleted Value if the data subject has set software toautomatically delete (e.g., immediately delete or route to a junkfolder) emails from the entity, and a value of 0 to Emails AutomaticallyDeleted Value if the data subject has not initiated such a setting.

As noted above, the system may allow users to customize the calculationabove by assigning a weighting value to any of the values included inthe Data Subject Disengagement Rating calculation. For example, thesystem may allow the user to assign a weighting value of 1.2 to EmailsOpened Value if that particular user believes that this factor should beweighted 20% higher than usual in the calculation.

In various embodiments, the system is configured to, in response todetermining that the data subject no longer actively does business withthe entity, automatically generate, populate, and/or submit a datasubject access request to the entity. In various embodiments, the datasubject access request may include: (1) a request to delete some or allof the data subject's personal data that is being processed by theentity (e.g., in the form of a “right to be forgotten” request); (2) arequest to rectify inaccurate personal data of the data subject that isbeing processed by the entity; (3) a request to access of a copy ofpersonal information of the data subject processed by the entity; (4) arequest to restrict the processing of the data subject's data by theentity; and/or (5) a request to transfer the data subject's data fromthe entity to a specified controller.

As a particular example, the system may generate a focused request tohave the entity delete all of the data subject's personal data that theentity is processing in conjunction with a particular service offered bythe entity. For example, at Step 4140, the system is configured tosubstantially automatically complete one or more data subject accessrequests on behalf of the data subject for one or more services that thedata subject no longer uses.

FIG. 42 depicts an exemplary data subject access request form that thesystem may substantially automatically generate, complete and/or submitfor the data subject on the data subject's behalf. As shown in thisfigure, the system may complete information such as, for example: (1)what type of requestor the data subject is (e.g., employee, customer,etc.); (2) what the request involves (e.g., deleting data, etc.); (3)the requestor's first name; (4) the requestor's last name; (5) therequestor's email address; (6) the requestor's telephone number; (7) therequestor's home address; and/or (8) one or more details associated withthe request. In particular embodiments, the system is configured to usean index of information about a particular entity or service to automatefilling out the data subject access request.

In various embodiments, the system may receive at least some data fromthe data subject in order to complete the data subject access request.In other embodiments, the system is configured to scan one or moree-mails from the subject company to obtain one or more particular piecesof information for use in filling out the data subject access request(e.g., by identifying a shipping address in a particular e-mail, billingaddress, first name, last name, and/or phone number of the data subjectfrom a previous order that the data subject placed with the subjectcompany, etc.). In particular embodiments, the system may automaticallyidentify all of the information needed to populate the data subjectaccess request by identifying the information from within one or moreindividual electronic correspondence associated with the data subject(e.g., one or more texts or emails from the entity to the data subject).

In particular embodiments, the system may be configured to send amessage to the data subject (e.g., via e-mail) prior to automaticallycompleting the data subject access request. The message may, forexample, require the data subject to confirm that the data subject wouldlike the system to complete the request on the data subject's behalf. Invarious embodiments, in response to the data subject confirming that thedata subject would like the system to complete the request, the systemautomatically populates the request and submits the request to theentity on the data subject's behalf.

In other embodiments, the system may automatically submit the requestwithout explicit authorization from the data subject (e.g., the datasubject may have provided a blanket authorization for submitting suchrequests when configuring the system's settings.)

In some embodiments, the Email Scanning System may comprise a thirdparty system that is independent from the one or more subject entities.In such embodiments, the Email Scanning System may be implemented aspart of a service for data subjects who may desire to exercise one ormore privacy rights, but who aren't necessarily aware of which companiesmay be storing or processing their personal data, or who don't want tospend the time to submit data subject access requests manually.Similarly, various embodiments of the system may be implemented as partof a service that advantageously provides a data subject with anautomated way of submitting data subject access requests to subjectcompanies whose services the data subject no longer uses.

In still other embodiments, the system may be provided by a subjectentity (e.g., company) for use by data subjects. Because subjectcompanies are subject to requirements (e.g., in the form of laws andregulations) related to the storage and processing of personal data, itmay benefit the subject company to no longer burden itself with storingor processing data related to a data subject that is no longerpurchasing the subject entity's goods or utilizing the subject entity'sservices (e.g., that is no longer actively engaged with the entity). Insuch embodiments, the system may be configured to: (1) substantiallyautomatically submit the data subject access request; and (2) respond toand fulfill the data subject access request (e.g., the same system orrelated systems utilized by a particular subject entity may beconfigured to both submit and fulfill the data subject access request).In other embodiments, the subject entity may unilaterally modify (e.g.,edit or delete) the data subject's personal data within one or more ofits systems in response to determining that the data subject does notactively do business with the subject entity.

In particular embodiments for example, in response to the systemsubmitting a request to delete the data subject's personal data from asubject entity's systems, the system may: (1) automatically determinewhere the data subject's personal data, which is processed by thesubject entity, is stored; and (2) in response to determining thelocation of the data (e.g., which may be on multiple computing systems),automatically facilitate the deletion of the data subject's personaldata from the various systems (e.g., by automatically assigning one ormore tasks to delete data across one or more computer systems toeffectively delete the data subject's personal data from the systems).In particular embodiments, the step of facilitating the deletion of thepersonal data may comprise, for example: (1) overwriting the data inmemory; (2) marking the data for overwrite; (2) marking the data as free(e.g., and deleting a directory entry associated with the data); and/or(3) any other suitable technique for deleting the personal data. Inparticular embodiments, as part of this process, the system uses anappropriate data model (see discussion above) to efficiently determinewhere all of the data subject's personal data is stored.

Automated Data Subject Verification

In various embodiments, before a data subject request can be processed,the data subject's identity may need to be verified. In variousembodiments, the system provides a mechanism to automatically detect thetype of authentication required for a particular data subject based onthe type of Data Subject Access Request being made and automaticallyissues a request to the data subject to verify their identity againstthat form of identification. For example, a subject rights request mightonly require two types of authentication, but a deletion request mayrequire four types of data to verify authentication. The system mayautomatically detect which is type of authentication is required basedon the DSAR and send an appropriate request to the data subject toverify their identity.

Stated more particularly, when processing a data subject access request,the system may be configured to verify an identity of the data subjectprior to processing the request (e.g., or as part of the processingstep). In various embodiments, confirming the identity of the datasubject may, for example, limit a risk that a third-party or otherentity may gain unlawful or unconsented to access to the requestor'spersonal data. The system may, for example, limit processing andfulfillment of requests relating to a particular data subject torequests that are originated by (e.g., received from) the particulardata subject. When processing a data subject access request, the systemmay be configured to use various reasonable measures to verify theidentity of the data subject who requests access (e.g., in particular inthe context of online services and online identifiers). In particularembodiments, the system is configured to substantially automaticallyvalidate an identity of a data subject when processing the data subjectaccess request.

For example, in particular embodiments, the system may be configured tosubstantially automatically (e.g., automatically) authenticate and/orvalidate an identity of a data subject using any suitable technique.These techniques may include, for example: (1) one or more credit-basedand/or public- or private-information-based verification techniques; (2)one or more company verification techniques (e.g., in the case of abusiness-to-business data subject access request); (3) one or moretechniques involving integration with a company's employeeauthentication system; (4) one or more techniques involving a company's(e.g., organization's) consumer portal authentication process; (5) etc.Various exemplary techniques for authenticating a data subject arediscussed more fully below.

In particular embodiments, when authenticating a data subject (e.g.,validating the data subject's identity), the system may be configured toexecute particular identity confirmation steps, for example, byinterfacing with one or more external systems (e.g., one or morethird-party data aggregation systems). For example, the system, whenvalidating a data subject's identity, may begin by verifying that aperson with the data subject's name, address, social security number, orother identifying characteristic (e.g., which may have been provided bythe data subject as part of the data subject access request) actuallyexists. In various embodiments, the system is configured to interfacewith (e.g., transmit a search request to) one or more credit reportingagencies (e.g., Experian, Equifax, TransUnion, etc.) to confirm that aperson with one or more characteristics provided by the data subjectexists. The system may, for example, interface with such creditreporting agencies via a suitable plugin (e.g., software plugin).Additionally, there might be a verification on behalf of a trustedthird-party system (e.g., the controller).

In still other embodiments, the system may be configured to utilize oneor more other third-party systems (e.g., such as LexisNexis, IDology,RSA, etc.), which may, for example, compile utility and phone bill data,property deeds, rental agreement data, and other public records forvarious individuals. The system may be configured to interface with oneor more such third-party systems to confirm that a person with one ormore characteristics provided by the data subject exists.

After the step of confirming the existence of a person with the one ormore characteristics provided by the data subject, the system may beconfigured to confirm that the person making the data subject accessrequest is, in fact, the data subject. The system may, for example,verify that the requestor is the data subject by prompting the requestorto answer one or more knowledge-based authentication questions (e.g.,out-of-wallet questions). In particular embodiments, the system isconfigured to utilize one or more third-party services as a source ofsuch questions (e.g., any of the suitable third-party sources discussedimmediately above). The system may use third-party data from the one ormore third-party sources to generate one or more questions. These one ormore questions may include questions that a data subject should know ananswer to without knowing the question ahead of time (e.g., one or moreprevious addresses, a parent or spouse name and/or maiden name, etc.).

FIG. 46 depicts an exemplary identity verification questionnaire. As maybe understood from this figure, an identity verification questionnairemay include one or more questions whose responses include data that thesystem may derive from one or more credit agencies or other third-partydata aggregation services (e.g., such as previous street addresses,close associates, previous cities lived in, etc.). In particularembodiments, the system is configured to provide these one or morequestions to the data subject in response to receiving the data subjectaccess request. In other embodiments, the system is configured to promptthe data subject to provide responses to the one or more questions at alater time (e.g., during processing of the request). In particular otherembodiments, the system is configured to substantially automaticallycompare one or more pieces of information provided as part of the datasubject access request to one or more pieces of data received from athird-party data aggregation service in order to substantiallyautomatically verify the requestor's identity.

In still other embodiments, the system may be configured to prompt arequestor to provide one or more additional pieces of information inorder to validate the requestor's identity. This information mayinclude, for example: (1) at least a portion of the requestor's socialsecurity number (e.g., last four digits); (2) a name and/or place ofbirth of the requestor's father; (3) a name, maiden name, and/or placeof birth of the requestor's mother; and/or (4) any other informationwhich may be useful for confirming the requestor's identity (e.g., suchas information available on the requestor's birth certificate). In otherembodiments, the system may be configured to prompt the requestor toprovide authorization for the company to check the requestor's socialsecurity or other private records (e.g., credit check authorization,etc.) to obtain information that the system may use to confirm therequestor's identity. In other embodiments, the system may prompt theuser to provide one or more images (e.g., using a suitable mobilecomputing device) of an identifying document (e.g., a birth certificate,social security card, driver's license, etc.).

The system may, in response to a user providing one or more responsesthat matches information that the system receives from one or morethird-party data aggregators or through any other suitable background,credit, or other search, substantially automatically authenticate therequestor as the data subject. The system may then continue processingthe data subject's request, and ultimately fulfill their request.

In particular embodiments, such as embodiments in which the requestorincludes a business (e.g., as in a business to business data subjectaccess request), the system may be configured to authenticate therequesting business using one or more company verification techniques.These one or more company validation techniques may include, forexample, validating a vendor contract (e.g., between the requestingbusiness and the company receiving the data subject access request);receiving a matching token, code, or other unique identifier provided bythe company receiving the data subject access request to the requestingbusiness; receiving a matching file in possession of both the requestingbusiness and the company receiving the data subject access request;receiving a signed contract, certificate (e.g., digital or physical), orother document memorializing an association between the requestingbusiness and the company receiving the data subject access request;and/or any other suitable method of validating that a particular requestis actually made on behalf of the requesting business (e.g., byrequesting the requesting business to provide one or more pieces ofinformation, one or more files, one or more documents, etc. that mayonly be accessible to the requesting business).

In other embodiments, the system may be configured to authenticate arequest via integration with a company's employee or customer (e.g.,consumer) authentication process. For example, in response to receivinga data subject access request that indicates that the data subject is anemployee of the company receiving the data subject access request, thesystem may be configured to prompt the employee to login to thecompany's employee authentication system (e.g., Okta, Azure, AD, etc.)In this way, the system may be configured to authenticate the requestorbased at least in part on the requestor successfully logging into theauthentication system using the data subject's credentials. Similarly,in response to receiving a data subject access request that indicatesthat the data subject is a customer of the company receiving the datasubject access request, the system may be configured to prompt thecustomer to login to an account associated with the company (e.g., via aconsumer portal authentication process). In a particular example, thismay include, for example, an Apple ID (for data subject access requestsreceived by Apple). In this way, the system may be configured toauthenticate the requestor based at least in part on the requestorsuccessfully logging into the authentication system using the datasubject's credentials. In some embodiments, the system may be configuredto require the requestor to login using two-factor authentication orother suitable existing employee or consumer authentication process.

Data Subject Blacklist

In various embodiments, a particular organization may not be required torespond to a data subject access request that originates (e.g., isreceived from) a malicious requestor. A malicious requestor may include,for example: (1) a requestor (e.g., an individual) that submitsexcessive or redundant data subject access requests; (2) a group ofrequestors such as researchers, professors, students, NGOs, etc. thatsubmit a plurality of requests for reasons other than those reasonsprovided by policy, law, etc.; (3) a competitor of the company receivingthe data subject access request that is submitting such requests to tieup the company's resources unnecessarily; (4) a terrorist or otherorganization that may spam requests to disrupt the company's operationand response to valid requests; and/or (5) any other request that mayfall outside the scope of valid requests made for reasons proscribed bypublic policy, company policy, or law. In particular embodiments, thesystem is configured to maintain a blacklist of such maliciousrequestors.

In particular embodiments, the system is configured to track a source ofeach data subject access request and analyze each source to identifysources from which: (1) the company receives a large volume of requests;(2) the company receives a large number of repeat requests; (3) etc.These sources may include, for example: (1) one or more particular IPaddresses; (2) one or more particular domains; (3) one or moreparticular countries; (4) one or more particular institutions; (5) oneor more particular geographic regions; (6) etc. In various embodiments,in response to analyzing the sources of the requests, the system mayidentify one or more sources that may be malicious (e.g., are submittingexcessive requests).

In various embodiments, the system is configured to maintain a databaseof the identified one or more sources (e.g., in computer memory). Inparticular embodiments, the database may store a listing of identities,data sources, etc. that have been blacklisted (e.g., by the system). Inparticular embodiments, the system is configured to, in response toreceiving a new data subject access request, cross reference the requestwith the blacklist to determine if the requestor is on the blacklist oris making the request from a blacklisted source. The system may then, inresponse to determining that the requestor or source is blacklisted,substantially automatically reject the request. In particularembodiments, the blacklist cross-referencing step may be part of therequestor authentication (e.g., verification) discussed above. Invarious embodiments, the system may be configured to analyze requestdata on a company by company basis to generate a blacklist. In otherembodiments, the system may analyze global data (e.g., all datacollected for a plurality of companies that utilize the data subjectaccess request fulfillment system) to generate the blacklist.

In particular embodiments, the system may be configured to fulfill datasubject access requests for the purpose of providing a data subject withinformation regarding what data the company collects and for whatpurpose, for example, so the data subject can ensure that the company iscollecting data for lawful reasons. As such, the system may beconfigured to identify requestors and other sources of data requeststhat are made for other reasons (e.g., one or more reasons that wouldnot obligate the company to respond to the request). These reasons mayinclude, for example, malicious or other reasons such as: (1) researchby an academic institution by one or more students or professors; (2)anticompetitive requests by one or more competitors; (3) requests bydisgruntled former employees for nefarious reasons; (4) etc.

In particular embodiments, the system may, for example, maintain adatabase (e.g., in computer memory) of former employees. In otherembodiments, the system may, for example: (1) identify a plurality of IPaddresses associated with a particular entity (e.g., academicorganization, competitor, etc.); and (2) substantially automaticallyreject a data subject access request that originates from the pluralityof IP addresses. In such embodiments, the system may be configured toautomatically add such identified IP addresses and/or domains to theblacklist.

In still other embodiments, the system is configured to maintain alisting of blacklisted names of particular individuals. These mayinclude, for example, one or more individuals identified (e.g., by anorganization or other entity) as submitting malicious data subjectaccess requests).

FIG. 47 depicts a queue of pending data subject access requests. Asshown in this figure, the first three listed data subject accessrequests are new and require verification before processing andfulfillment can begin. As shown in this figure, a user (e.g., such as aprivacy officer or other privacy controller) may select a particularrequest, and select an indicia for verifying the request. The user mayalso optionally select to reject the request. FIG. 48 depicts anauthentication window that enables the user to authenticate a particularrequest. In various embodiments, the user may provide an explanation ofwhy the user is authenticating the request (e.g., because the requestorsuccessfully completed on or more out-of-wallet questions or for anyother suitable reason). The user may further submit one or moreattachments to support the verification. In this way, the system may beconfigured to document that the authentication process was performed foreach request (e.g., in case there was an issue with improperlyfulfilling a request, the company could show that they are followingprocedures to prevent such improper processing). In other embodiments,the system may enable the user to provide similar support when rejectinga request (e.g., because the requestor was blacklisted, made excessiverequests, etc.).

Data Subject Access Request Fulfillment Cost Determination

In various embodiments, as may be understood in light of thisdisclosure, fulfilling a data subject access request may be particularlycostly. In some embodiments, a company may store data regarding aparticular data subject in multiple different locations for a pluralityof different reasons as part of a plurality of different processing andother business activities. For example, a particular data subject may beboth a customer and an employee of a particular company or organization.Accordingly, in some embodiments, fulfilling a data subject accessrequest for a particular data subject may involve a plurality ofdifferent information technology (IT) professionals in a plurality ofdifferent departments of a particular company or organization. As such,it may be useful to determine a cost of a particular data subject accessrequest (e.g., particularly because, in some cases, a data subject isentitled to a response to their data subject access request as a matterof right at no charge).

In particular embodiments, in response to receiving a data subjectaccess request, the system may be configured to: (1) assign the requestto at least one privacy team member; (2) identify one or more IT teamsrequired to fulfill the request (e.g., one or more IT teams associatedwith one or more business units that may store personal data related tothe request); (3) delegate one or more subtasks of the request to eachof the one or more IT teams; (4) receive one or more time logs from eachindividual involved in the processing and fulfillment of the datasubject access request; (5) calculate an effective rate of eachindividual's time (e.g., based at least in part on the individual'ssalary, bonus, benefits, chair cost, etc.); (6) calculate an effectivecost of fulfilling the data subject access request based at least inpart on the one or more time logs and effective rate of each of theindividual's time; and (7) apply an adjustment to the calculatedeffective cost that accounts for one or more external factors (e.g.,overhead, etc.) in order to calculate a cost of fulfilling the datasubject access request.

In particular embodiments, the system is configured to substantiallyautomatically track an amount of time spent by each individual involvedin the processing and fulfillment of the data subject access request.The system may, for example, automatically track an amount of timebetween each individual opening and closing a ticket assigned to them aspart of their role in processing or fulfilling the data subject accessrequest. In other embodiments, the system may determine the time spentbased on an amount of time provided by each respective individual (e.g.,the individual may track their own time and submit it to the system).

In various embodiments, the system is configured to measure a cost ofeach particular data subject access request received, and analyze one ormore trends in costs of, for example: (1) data subject access requestsover time; (2) related data subject access requests; (3) etc. Forexample, the system may be configured to track and analyze cost andtime-to-process trends for one or more social groups, one or morepolitical groups, one or more class action groups, etc. In particular,the system may be configured to identify a particular group from whichthe system receives particularly costly data subject access request(e.g., former and/or current employees, members of a particular socialgroup, members of a particular political group, etc.).

In particular embodiments, the system may be configured to utilize datasubject access request cost data when processing, assigning, and/orfulfilling future data subject access requests (e.g., from a particularidentified group, individual, etc.). For example, the system may beconfigured to prioritize requests that are expected to be less costlyand time-consuming (e.g., based on past cost data) over requestsidentified as being likely more expensive. Alternatively, the system mayprioritize more costly and time-consuming requests over less costly onesin the interest of ensuring that the system is able to respond to eachrequest in a reasonable amount of time (e.g., within a time required bylaw, such as a thirty day period, or any other suitable time period).

Customer Satisfaction Integration with Data Subject Access Requests

In various embodiments, the system may be configured to collect customersatisfaction data, for example: (1) as part of a data subject accessrequest submission form; (2) when providing one or more results of adata subject access request to the data subject; or (3) at any othersuitable time. In various embodiments, the customer satisfaction datamay be collected in the form of a suitable survey, free-form responsequestionnaire, or other suitable satisfaction data collection format(e.g., thumbs up vs. thumbs down, etc.).

FIG. 49 depicts an exemplary customer satisfaction survey that may beincluded as part of a data subject access request form, provided alongwith the results of a data subject access request, provided in one ormore messages confirming receipt of a data subject access request, etc.As shown in the figure, the customer satisfaction survey may relate tohow likely a customer (e.g., a data subject) is to recommend the company(e.g., to which the data subject has submitted the request) to a friend(e.g., or colleague). In the example shown in FIG. 49 , the satisfactionsurvey may relate to a Net Promoter score (NPS), which may indicate aloyalty of a company's customer relationships. Generally speaking, theNet Promoter Score may measure a loyalty that exists between a providerand a consumer. In various embodiments, the provider may include acompany, employer, or any other entity. In particular embodiments, theconsumer may include a customer, employee, or other respondent to an NPSsurvey.

In particular embodiments, the question depicted in FIG. 49 is theprimary question utilized in calculating a Net Promoter Score (e.g.,“how likely is it that you would recommend our company/product/serviceto a friend or colleague?”). In particular embodiments, the question ispresented with responses ranging from 0 (not at all likely) to 10(extremely likely). In particular embodiments, the question may includeany other suitable scale. As may be understood from FIG. 49 , the systemmay be configured to assign particular categories to particular ratingson the 10 point scale. The system may be configured to track and storeresponses provided by consumers and calculate an overall NPS score forthe provider. The system may be further configured to generate a visualrepresentation of the NPS score, including a total number of responsesreceived for each particular score and category as shown in FIG. 49 .

In various embodiments, the system may be configured to measure datarelated to any other suitable customer satisfaction method (e.g., inaddition to NPS). By integrating a customer satisfaction survey with thedata subject access request process, the system may increase a number ofconsumers that provide one or more responses to the customersatisfaction survey. In particular embodiments, the system is configuredto require the requestor to respond to the customer satisfaction surveyprior to submitting the data subject access request.

Identifying and Deleting Orphaned Data

In particular embodiments, an Orphaned Data Action System is configuredto analyze one or more data systems (e.g., data assets), identify one ormore pieces of personal data that are one or more pieces of personaldata that are not associated with one or more privacy campaigns of theparticular organization, and notify one or more individuals of theparticular organization of the one or more pieces of personal data thatare one or more pieces of personal data that are not associated with oneor more privacy campaigns of the particular organization. In variousembodiments, one or more processes described herein with respect to theorphaned data action system may be performed by any suitable server,computer, and/or combination of servers and computers.

Various processes performed by the Orphaned Data Action System may beimplemented by an Orphaned Data Action Module 5000. Referring to FIG. 50, in particular embodiments, the system, when executing the OrphanedData Action Module 5000, is configured to: (1) access one or more dataassets of a particular organization; (2) scan the one or more dataassets to generate a catalog of one or more privacy campaigns and one ormore pieces of personal information associated with one or moreindividuals; (3) store the generated catalog in computer memory; (4)scan one or more data assets based at least in part on the generatedcatalog to identify a first portion of the one or more pieces ofpersonal data that are one or more pieces of personal data that are notassociated with the one or more privacy campaigns; (5) generate anindication that the first portion of one or more pieces of personal datathat are not associated with the one or more privacy campaigns of theparticular organization is to be removed from the one or more dataassets; (6) present the indication to one or more individuals associatedwith the particular organization; and (7) remove the first portion ofthe one or more pieces of personal data that are not associated with theone or more privacy campaigns of the particular organization from theone or more data assets.

When executing the Orphaned Data Action Module 5000, the system begins,at Step 5010, by accessing one or more data systems associated with theparticular entity. The particular entity may include, for example, aparticular organization, company, sub-organization, etc. In particularembodiments, the one or more data assets (e.g., data systems) mayinclude, for example, any entity that collects, processes, contains,and/or transfers data (e.g., a software application, “internet ofthings” computerized device, database, website, data-center, server,etc.). For example, a data asset may include any software or deviceutilized by a particular entity for data collection, processing,transfer, storage, etc.

In particular embodiments, the system is configured to identify andaccess the one or more data assets using one or more data modelingtechniques. As discussed more fully above, a data model may store thefollowing information: (1) the entity that owns and/or uses a particulardata asset; (2) one or more departments within the organization that areresponsible for the data asset; (3) one or more software applicationsthat collect data (e.g., personal data) for storage in and/or use by thedata asset; (4) one or more particular data subjects (or categories ofdata subjects) that information is collected from for use by the dataasset; (5) one or more particular types of data that are collected byeach of the particular applications for storage in and/or use by thedata asset; (6) one or more individuals (e.g., particular individuals ortypes of individuals) that are permitted to access and/or use the datastored in, or used by, the data asset; (7) which particular types ofdata each of those individuals are allowed to access and use; and (8)one or more data assets (destination assets) that the data istransferred to for other use, and which particular data is transferredto each of those data assets.

As may be understood in light of this disclosure, the system may utilizea data model (e.g., or one or more data models) of data assetsassociated with a particular entity to identify and access the one ormore data assets associated with the particular entity.

Continuing to Step 5020, the system is configured to scan the one ormore data assets to generate a catalog of one or more privacy campaignsand one or more pieces of personal information associated with one ormore individuals. The catalog may include a table of the one or moreprivacy campaigns within the data assets of the particular entity and,for each privacy campaign, the one or more pieces of personal datastored within the data assets of the particular entity that areassociated with the particular privacy campaign. In any embodimentdescribed herein, personal data may include, for example: (1) the nameof a particular data subject (which may be a particular individual); (2)the data subject's address; (3) the data subject's telephone number; (4)the data subject's e-mail address; (5) the data subject's socialsecurity number; (6) information associated with one or more of the datasubject's credit accounts (e.g., credit card numbers); (7) bankinginformation for the data subject; (8) location data for the data subject(e.g., their present or past location); (9) internet search history forthe data subject; and/or (10) any other suitable personal information,such as other personal information discussed herein.

In some implementations, the system may access, via one or more computernetworks, one or more data models that map an association between one ormore pieces of personal data stored within one or more data assets ofthe particular entity and one or more privacy campaigns of theparticular entity. As further described herein, the data models mayaccess the data assets of the particular entity and use one or moresuitable data mapping techniques to link, or otherwise associate, theone or more pieces of personal data stored within one or more dataassets of the particular entity and one or more privacy campaigns of theparticular entity. In some implementations, the one or more data modelsmay link, or otherwise associate, a particular individual and each pieceof personal data of that particular individual that is stored on one ormore data assets of the particular entity.

In some embodiments, the system is configured to generate and populate adata model based at least in part on existing information stored by thesystem (e.g., in one or more data assets), for example, using one ormore suitable scanning techniques. In still other embodiments, thesystem is configured to access an existing data model that maps personaldata stored by one or more organization systems to particular associatedprocessing activities. In some implementations, the system is configuredto generate and populate a data model substantially on the fly (e.g., asthe system receives new data associated with particular processingactivities). For example, a particular processing activity (e.g.,privacy campaign) may include transmission of a periodic advertisinge-mail for a particular company (e.g., a hardware store). A data modelmay locate the collected and stored email addresses for customers thatelected to receive (e.g., consented to receipt of) the promotional emailwithin the data assets of the particular entity, and then map each ofthe stored email addresses to the particular processing activity (i.e.,the transmission of a periodic advertising e-mail) within the dataassets of the particular entity.

Next, at Step 5030, the system is configured to store the generatedcatalog of one or more privacy campaigns and one or more pieces ofpersonal information associated with one or more individuals. In someimplementations, the system may receive an indication that a newprocessing activity (e.g., privacy campaign) has been launched by theparticular entity. In response to receiving the indication, the systemmay modify the one or more data models to map an association between (i)one or more pieces of personal data associated with one or moreindividuals obtained in connection with the new privacy campaign and(ii) the new privacy campaign initiated by the particular entity. As thesystem receives one or more pieces of personal data associated with oneor more individuals (e.g., an email address signing up to receiveinformation from the particular entity), then the data model associatedwith the particular processing activity may associate the receivedpersonal data with the privacy campaign. In some implementations, one ormore data assets may already include the particular personal data (e.g.,email address) because the particular individual, for example,previously provided their email address in relation to a differentprivacy campaign of the particular entity. In response, the system mayaccess the particular personal data and associate that particularpersonal data with the new privacy campaign.

At Step 5040, the system is configured to scan one or more data assetsbased at least in part on the generated catalog to identify a firstportion of the one or more pieces of personal data that are one or morepieces of personal data that are not associated with the one or moreprivacy campaigns. In various embodiments, the system may use thegenerated catalogue to scan the data assets of the particular entity toidentify personal data that has been collected and stored using one ormore computer systems operated and/or utilized by a particularorganization where the personal data is not currently being used as partof any privacy campaigns, processing activities, etc. undertaken by theparticular organization. The one or more pieces of personal data thatare not associated with the one or more privacy campaigns may be aportion of the personal data that is stored by the particular entity. Insome implementations, the system may analyze the data models to identifythe one or more pieces of personal data that are not associated with theone or more privacy campaigns.

When the particular privacy campaign, processing activity, etc. isterminated or otherwise discontinued, the system may determine if any ofthe associated personal data that has been collected and stored by theparticular organization is now orphaned data. In some implementations,in response to the termination of a particular privacy campaign and/orprocessing activity, (e.g., manually or automatically), the system maybe configured to scan one or more data assets based at least in part onthe generated catalog or analyze the data models to determine whetherany of the personal data that has been collected and stored by theparticular organization is now orphaned data (e.g., whether any personaldata collected and stored as part of the now-terminated privacy campaignis being utilized by any other processing activity, has some other legalbasis for its continued storage, etc.). In some implementations, thesystem may generate an indication that one or more pieces of personaldata that are associated with the terminated one or more privacycampaigns are included in the portion of the one or more pieces ofpersonal data (e.g., orphaned data).

In additional implementations, the system may determine that aparticular privacy campaign, processing activity, etc. has not beenutilized for a period of time (e.g., a day, a month, a year). Inresponse, the system may be configured to terminate the particularprocessing activity, processing activity, etc. In some implementations,in response to the system determining that a particular processingactivity has not been utilized for a period of time, the system mayprompt one or more individuals associated with the particular entity toindicate whether the particular privacy campaign should be terminated orotherwise discontinued.

For example, a particular processing activity may include transmissionof a periodic advertising e-mail for a particular company (e.g., ahardware store). As part of the processing activity, the particularcompany may have collected and stored e-mail addresses for customersthat elected to receive (e.g., consented to the receipt of) thepromotional e-mails. In response to determining that the particularcompany has not sent out any promotional e-mails for at least aparticular amount of time (e.g., for at least a particular number ofmonths), the system may be configured to: (1) automatically terminatethe processing activity; (2) identify any of the personal data collectedas part of the processing activity that is now orphaned data (e.g., thee-mail addresses); and (3) automatically delete the identified orphaneddata. The processing activity may have ended for any suitable reason(e.g., because the promotion that drove the periodic e-mails has ended).As may be understood in light of this disclosure, because the particularorganization no longer has a valid basis for continuing to store thee-mail addresses of the customers once the e-mail addresses are nolonger being used to send promotional e-mails, the organization may wishto substantially automate the removal of personal data stored in itscomputer systems that may place the organization in violation of one ormore personal data storage rules or regulations.

Continuing to Step 5050, the system is configured to generate anindication that the portion of one or more pieces of personal data thatare not associated with the one or more privacy campaigns of theparticular entity is to be removed from the one or more data assets. AtStep 5060, the system is configured to present the indication to one ormore individuals associated with the particular entity. The indicationmay be an electronic notification to be provided to an individual (e.g.,privacy officer) associated with the particular entity. The electronicnotification may be, for example, (1) a notification within a softwareapplication (e.g., a data management system for the one or more dataassets of the particular entity), (2) an email notification, (3) etc.

In some implementations, the indication may enable the individual (e.g.,privacy officer of the particular entity) to select a set of the one ormore pieces of personal data of the portion of the one or more pieces ofpersonal data to retain based on one or more bases to retain the set ofthe one or more pieces of personal data.

In particular embodiments, the system may prompt the one or moreindividuals to provide one or more bases to retain the first set of theone or more pieces of personal data of the first portion of the one ormore pieces of personal data that are not associated with the one ormore privacy campaigns. In some implementations, in response toreceiving the provided one or more valid bases to retain the first setof the one or more pieces of personal data from the one or moreindividuals associated with the particular entity, submitting theprovided one or more valid bases to retain the first set of the one ormore pieces of personal data to one or more second individualsassociated with the particular entity for authorization. In response,the system may retain the first set of the one or more pieces ofpersonal data of the first portion of the one or more pieces of personaldata from the one or more individuals associated with the particularentity. Further, the system may remove a second set of the one or morepieces of personal data of the first portion of the one or more piecesof personal data that are not associated with the one or more privacycampaigns from the one or more data assets. In particular embodiments,the second set of the one or more pieces of personal data may bedifferent from the first set of the one or more pieces of personal data.

Continuing to Step 5070, the system is configured to remove, by one ormore processors, the first portion of the one or more pieces of personaldata that are not associated with the one or more privacy campaigns ofthe particular entity from the one or more data assets.

Data Testing to Confirm Deletion Under a Right to Erasure

In particular embodiments, a Personal Data Deletion System is configuredto: (1) at least partially automatically identify and delete personaldata that an entity is required to erase under one or more of theconditions discussed above; and (2) perform one or more data tests afterthe deletion to confirm that the system has, in fact, deleted anypersonal data associated with the data subject.

Various processes performed by the Personal Data Deletion System may beimplemented by a Personal Data Deletion and Testing Module 5100.Referring to FIG. 51 , in particular embodiments, the system, whenexecuting the Personal Data Deletion and Testing Module 5100, isconfigured to: (1) receive an indication that the entity has completedan erasure of one or more pieces of personal data associated with thedata subject under a right of erasure; (2) initiate a test interactionbetween the data subject and the entity, the test interaction requiringa response from the entity to the data subject; (3) determine whetherone or more system associated with the entity have initiated a testinteraction response to the data subject based at least in part on thetest interaction; (4) in response to determining that the one or moresystems associated with the entity have initiated the test interactionresponse, (a) determine that the entity has not completed the erasure ofthe one or more pieces of personal data associated with the data subjectand (b) automatically take one or more actions with regard to thepersonal data associated with the data subject.

When executing the Personal Data Deletion and Testing Module 5100, thesystem begins, at Step 5110, by receiving an indication that the entityhas completed an erasure of one or more pieces of personal dataassociated with the data subject under a right of erasure. Theparticular entity may include, for example, a particular organization,company, sub-organization, etc. In particular embodiments, the one ormore computers systems may be configured to store (e.g., in memory) anindication that the data subject's request to delete any of theirpersonal data stored by the one or more computers systems has beenprocessed. Under various legal and industry policies/standards, theorganization may have a certain period of time (e.g., a number of days)in order to comply with the one or more requirements related to thedeletion or removal of personal data in response to receiving a requestfrom the data subject or in response to identifying one or more of theconditions requiring deletion discussed above. In response to thereceiving an indication that the deletion request for the data subject'spersonal data has been processed or the certain period of time(described above) has passed, the system may be configured to perform adata test to confirm the deletion of the data subject's personal data.

Continuing to Step 5120, in response to receiving the indication thatthe entity has completed the erasure, the system is configured toinitiate a test interaction between the data subject and the entity, thetest interaction requiring a response from the entity to the datasubject. In particular embodiments, when performing the data test, thesystem may be configured to provide an interaction request to the entityon behalf of the data subject. In particular embodiments, theinteraction request may include, for example, a request for one or morepieces of data associated with the data subject (e.g., accountinformation, etc.). In various embodiments, the interaction request is arequest to contact the data subject (e.g., for any suitable reason). Thesystem may, for example, be configured to substantially automaticallycomplete a contact-request form (e.g., a webform made available by theentity) on behalf of the data subject. In various embodiments, whenautomatically completing the form on behalf of the data subject, thesystem may be configured to only provide identifying data, but not toprovide any contact data. In response to submitting the interactionrequest (e.g., submitting the webform), the system may be configured todetermine whether the one or more computers systems have generatedand/or transmitted a response to the data subject. The system may beconfigured to determine whether the one or more computers systems havegenerated and/or transmitted the response to the data subject by, forexample, analyzing one or more computer systems associated with theentity to determine whether the one or more computer systems havegenerated a communication to the data subject (e.g., automatically) fortransmission to an e-mail address or other contact method associatedwith the data subject, generated an action-item for an individual tocontact the data subject at a particular contact number, etc.

To perform the data test, for example, the system may be configured to:(1) access (e.g., manually or automatically) a form for the entity(e.g., a web-based “Contact Us” form); (2) input a unique identifierassociated with the data subject (e.g., a full name or customer IDnumber) without providing contact information for the data subject(e.g., mailing address, phone number, email address, etc.); and (3)input a request, within the form, for the entity to contact the datasubject to provide information associated with the data subject (e.g.,the data subject's account balance with the entity). In response tosubmitting the form to the entity, the system may be configured todetermine whether the data subject is contacted (e.g., via a phone callor email) by the one or more computers systems (e.g., automatically). Insome implementations, completing the contact-request form may includeproviding one or more pieces of identifying data associated with thedata subject, the one or more pieces of identifying data comprising dataother than contact data. In response to determining that the datasubject has been contacted following submission of the form, the systemmay determine that the one or more computers systems have not fullydeleted the data subject's personal data (e.g., because the one or morecomputers systems must still be storing contact information for the datasubject in at least one location).

In particular embodiments, the system is configured to generate one ormore test profiles for one or more test data subjects. For each of theone or more test data subjects, the system may be configured to generateand store test profile data such as, for example: (1) name; (2) address;(3) telephone number; (4) e-mail address; (5) social security number;(6) information associated with one or more credit accounts (e.g.,credit card numbers); (7) banking information; (8) location data; (9)internet search history; (10) non-credit account data; and/or (11) anyother suitable test data. The system may then be configured to at leastinitially consent to processing or collection of personal data for theone or more test data subjects by the entity. The system may thenrequest deletion of data of any personal data associated with aparticular test data subject. In response to requesting the deletion ofdata for the particular test data subject, the system may then take oneor more actions using the test profile data associated with theparticular test data subjects in order to confirm that the one or morecomputers systems have, in fact, deleted the test data subject'spersonal data (e.g., any suitable action described herein). The systemmay, for example, be configured to: (1) initiate a contact request onbehalf of the test data subject; (2) attempt to login to one or moreuser accounts that the system had created for the particular test datasubject; and/or (3) take any other action, the effect of which couldindicate a lack of complete deletion of the test data subject's personaldata.

Next, at Step 5130, in response to initiating the test interaction, thesystem is configured to determine whether one or more system associatedwith the entity have initiated a test interaction response to the datasubject based at least in part on the test interaction. In response todetermining that the entity has generated a response to the testinteraction, the system may be configured to determine that the entityhas not complied with the data subject's request (e.g., deletion oftheir personal data from the one or more computers systems). Forexample, if the test interaction requests for the entity to locate andprovide any personal data the system has stored related to the datasubject, then by the system providing a response that includes one ormore pieces of personal data related to the data subject, the system maydetermine that the one or more computers systems have not complied withthe request. As described above, the request may be an erasure of one ormore pieces of personal data associated with the data subject under aright of erasure. In some implementations, the test interaction responsemay be any response that includes any one of the one or more pieces ofpersonal data the system indicated was erased under the right oferasure. In some implementations, the test interaction response may notinclude response that indicates that the one or more pieces of personaldata the system indicated was erased under the right of erasure was notfound or accessed by the system.

At Step 5140, in response to determining that the one or more systemsassociated with the entity have initiated the test interaction responsethe system is configured to (a) determine that the one or more computerssystems have not completed the erasure of the one or more pieces ofpersonal data associated with the data subject, and (b) automaticallytake one or more actions with regard to the personal data associatedwith the data subject. In response to determining that the one or morecomputers systems have not fully deleted a data subject's (e.g., or testdata subject's) personal data, the system may then be configured, inparticular embodiments, to: (1) flag the data subject's personal datafor follow up by one or more privacy officers to investigate the lack ofdeletion; (2) perform one or more scans of one or more computing systemsassociated with the entity to identify any residual personal data thatmay be associated with the data subject; (3) generate a reportindicating the lack of complete deletion; and/or (4) take any othersuitable action to flag the data subject, personal data, initial requestto be forgotten, etc. for follow up.

In various embodiments, the one or more actions may include: (1)identifying the one or more pieces of personal data associated with thedata subject that remain stored in the one or more computer systems ofthe entity; (2) flagging the one or more pieces of personal dataassociated with the data subject that remain stored in the one or morecomputer systems of the entity; and (3) providing the flagged one ormore pieces of personal data associated with the data subject thatremain stored in the one or more computer systems of the entity to anindividual associated with the entity.

In various embodiments, the system may monitor compliance by aparticular entity with a data subject's request to delete the datasubject's personal data from the one or more computers systemsassociated with a particular entity. The system may, for example, beconfigured to test to ensure the data has been deleted by: (1)submitting a unique token of data through a webform to a system (e.g.,mark to); (2) in response to passage of an expected data retention time,test the system by calling into the system after the passage of the dataretention time to search for the unique token. In response to findingthe unique token, the system may be configured to determine that thedata has not been properly deleted.

The system may provide a communication to the entity that includes aunique identifier associated with the data subject, is performed withoutusing a personal communication data platform, prompts the entity toprovide a response by contacting the data subject via a personalcommunication data platform. In response to providing the communicationto the entity, the system may determine whether the data subject hasreceived a response via the personal communication data platform. Thesystem may, in response to determining that the data subject hasreceived the response via the personal communication data platform,determine that the one or more computers systems have not complied withthe data subject's request for deletion of their personal data. Inresponse, the system may generate an indication that the one or morecomputers systems have not complied with the data subject's request fordeletion of their personal data by the entity, and digitally store theindication that the one or more computers systems have not complied withthe data subject's request for deletion of their personal data incomputer memory.

Automatic Preparation for Remediation

In particular embodiments, a Risk Remediation System is configured tosubstantially automatically determine whether to take one or moreactions in response to one or more identified risk triggers. Forexample, an identified risk trigger may be that a data asset for anorganization is hosted in only one particular location therebyincreasing the scope of risk if the location were infiltrated (e.g., viacybercrime). In particular embodiments, the system is configured tosubstantially automatically perform one or more steps related to theanalysis of and response to the one or more potential risk triggersdiscussed above. For example, the system may substantially automaticallydetermine a relevance of a risk posed by (e.g., a risk level) the one ormore potential risk triggers based at least in part on one or morepreviously-determined responses to similar risk triggers. This mayinclude, for example, one or more previously determined responses forthe particular entity that has identified the current risk trigger, oneor more similarly situated entities, or any other suitable entity orpotential trigger.

Various processes performed by the Risk Remediation System may beimplemented by a Data Risk Remediation Module 5200. Referring to FIG. 52, in particular embodiments, the system, when executing the Data RiskRemediation Module 5200, is configured to access risk remediation datafor an entity that identifies one or more actions to remediate a risk inresponse to identifying one or more data assets of the entitypotentially affected by one or more risk triggers, receive an indicationof an update to the one or more data assets, identify one or moreupdated risk triggers for an entity based at least in part on the updateto the one or more data assets, determine, by using one or more datamodels associated with the risk remediation data, one or more updatedactions to remediate the one or more updated risk triggers, analyze theone or more updated risk triggers to determine a relevance of the riskposed to the entity by the one or more updated risk triggers, and updatethe risk remediation data to include the one or more updated actions toremediate the risk in response to identifying the one or more updatedrisk triggers.

When executing the Data Risk Remediation Module 5200, the system begins,at Step 5210, by accessing risk remediation data for an entity thatidentifies one or more actions to remediate a risk in response toidentifying one or more data assets of the entity potentially affectedby one or more risk triggers. The particular entity may include, forexample, a particular organization, company, sub-organization, etc. Theone or more data assets may include personal data for clients orcustomers. In embodiment described herein, personal data may include,for example: (1) the name of a particular data subject (which may be aparticular individual); (2) the data subject's address; (3) the datasubject's telephone number; (4) the data subject's e-mail address; (5)the data subject's social security number; (6) information associatedwith one or more of the data subject's credit accounts (e.g., creditcard numbers); (7) banking information for the data subject; (8)location data for the data subject (e.g., their present or pastlocation); (9) internet search history for the data subject; and/or (10)any other suitable personal information, such as other personalinformation discussed herein.

In some implementations, the system may include risk remediation dataassociated with one or more data assets. The risk remediation data maybe default or pre-configured risk remediation data that identifies oneor more actions to remediate a risk in response to identifying one ormore data assets of the entity potentially affected by one or more risktriggers. In some implementations, the system may have previouslyupdated and/or continuously update the risk remediation data. The riskremediation data may be updated and/or based on aggregate riskremediation data for a plurality of identified risk triggers from one ormore organizations, which may include the entity.

The system may analyze the aggregate risk remediation data to determinea remediation outcome for each of the plurality of identified risktriggers and an associated entity response to the particular identifiedrisk trigger of the plurality of identified risk triggers. Theremediation outcome is an indication of how well the entity responseaddressed the identified risk trigger. For example, the remediationoutcome can be a numerical (e.g., 1 to 10), an indication of the risktrigger after the entity response was performed (e.g., “high,” “medium,”or “low”). In response to analyzing the aggregate risk remediation datato determine a remediation outcome for each of the plurality ofidentified risk triggers and an associated entity response to theparticular identified risk trigger of the plurality of identified risktriggers, generating the data model of the one or more data models.

One or more data models for the system may be generated to indicate arecommended entity response based on each identified risk trigger. Theone or more risk remediation models base be generated in response toanalyzing the aggregate risk remediation data to determine a remediationoutcome for each of the plurality of identified risk triggers and anassociated entity response to the particular identified risk trigger ofthe plurality of identified risk triggers. Additionally, the riskremediation data for the entity may include the one or more riskremediation data models with an associated one or more data assets ofthe entity.

Continuing to Step 5220, the system is configured to receive anindication of an update to the one or more data assets. In particularembodiments, the system may indicate that a modification has beenperformed to the one or more data assets. In various embodiments, when aprivacy campaign, processing activity, etc. of the particularorganization is modified (e.g., add, remove, or update particularinformation), then the system may the risk remediation data for use infacilitating an automatic assessment of and/or response to futureidentified risk triggers. The modification may be an addition (e.g.,additional data stored to the one or more data assets), a deletion(e.g., removing data stored to the one or more data assets), or a change(e.g., editing particular data or rearranging a configuration of thedata associated with the one or more data assets. At Step 5230, thesystem is configured to identify one or more updated risk triggers foran entity based at least in part on the update to the one or more dataassets. The updated risk triggers may be anything that exposes the oneor more data assets of the entity to, for example, a data breach or aloss of data, among others. For example, an identified risk trigger maybe that a data asset for an organization is hosted in only oneparticular location thereby increasing the scope of risk if the locationwere infiltrated (e.g., via cybercrime).

At Step 5240, the system is configured to determine, by using one ormore data models associated with the risk remediation data, one or moreupdated actions to remediate the one or more updated risk triggers. Aspreviously described above, the one or more data models for the systemmay be generated to indicate a recommended entity response based on eachidentified risk trigger. The one or more risk remediation models base begenerated in response to analyzing the aggregate risk remediation datato determine a remediation outcome for each of the plurality ofidentified risk triggers and an associated entity response to theparticular identified risk trigger of the plurality of identified risktriggers.

At Step 5250, the system is configured to analyze the one or moreupdated risk triggers to determine a relevance of the risk posed to theentity by the one or more updated risk triggers. In particularembodiments, the system is configured to substantially automaticallyperform one or more steps related to the analysis of and response to theone or more potential risk triggers discussed above. For example, thesystem may substantially automatically determine a relevance of a riskposed by (e.g., a risk level) the one or more potential risk triggersbased at least in part on one or more previously-determined responses tosimilar risk triggers. This may include, for example, one or morepreviously determined responses for the particular entity that hasidentified the current risk trigger, one or more similarly situatedentities, or any other suitable entity or potential trigger. In someembodiments, the system is configured to determine, based at least inpart on the one or more data assets and the relevance of the risk,whether to take one or more updated actions in response to the one ormore updated risk triggers, and take the one or more updated actions toremediate the risk in response to identifying the one or more updatedrisk triggers.

Additionally, in some implementations, the system may calculate a risklevel based at least in part on the one or more updated risk triggers.The risk level may be compared to a threshold risk level for the entity.The threshold risk level may be pre-determined, or the entity may beable to adjust the threshold risk level (e.g., based on the type of datastored in the particular data asset, a number of data assets involved,etc.). In response to determining that the risk level is greater than orequal to the threshold risk level (i.e., a risk level that is defined asriskier than the threshold risk level or as risky as the threshold risklevel), updating the risk remediation data to include the one or moreupdated actions to remediate the risk in response to identifying the oneor more updated risk triggers. The risk level may be, for example, anumerical value (e.g., 1 to 10) or a described value (e.g., “low,”“medium,” or “high”), among others. In some implementations, calculatingthe risk level may be based at least in part on the one or more updatedrisk triggers further comprises comparing the one or more updated risktriggers to (i) one or more previously identified risk triggers, and(ii) one or more previously implemented actions to the one or morepreviously identified risk triggers.

At Step 5260, the system continues by updating the risk remediation datato include the one or more updated actions to remediate the risk inresponse to identifying the one or more updated risk triggers. Invarious embodiments, the system may automatically (e.g., substantiallyautomatically) update the risk remediation data.

In various embodiments, the system may identify one or more risktriggers for an entity based at least in part on the update to the firstdata asset of the entity, and in turn, identify a second data asset ofthe entity potentially affected by the one or more risk triggers basedat least in part on an association of a first data asset and the seconddata asset. The system may then determine, by using one or more datamodels, one or more first updated actions to remediate the one or moreupdated risk triggers for the first data asset, and determine, by usingone or more data models, one or more second updated actions to remediatethe one or more updated risk triggers for the second data asset. In someimplementations, the one or more first updated actions to remediate theone or more updated risk triggers for the first data asset may be thesame as or different from one or more second updated actions toremediate the one or more updated risk triggers for the second dataasset. Further, the system may generate (or update) risk remediationdata of the entity to include the one or more first updated actions andthe one or more second updated actions to remediate the one or morepotential risk triggers.

Central Consent Repository Maintenance and Data Inventory Linking

In particular embodiments, a Central Consent System is configured toprovide a third-party data repository system to facilitate the receiptand centralized storage of personal data for each of a plurality ofrespective data subjects, as described herein. Additionally, the CentralConsent System is configured to interface with a centralized consentreceipt management system.

Various processes performed by the Central Consent System may beimplemented by a Central Consent Module 5300. Referring to FIG. 53 , inparticular embodiments, the system, when executing the Central ConsentModule 5300, is configured to: identify a form used to collect one ormore pieces of personal data, determine a data asset of a plurality ofdata assets of the organization where input data of the form istransmitted, add the data asset to the third-party data repository withan electronic link to the form in response to a user submitting theform, create a unique subject identifier associated with the user,transmit the unique subject identifier (i) to the third-party datarepository and (ii) along with the form data provided by the user in theform, to the data asset, and digitally store the unique subjectidentifier (i) in the third-party data repository and (ii) along withthe form data provided by the user in the form, in the data asset.

When executing the Central Consent Module 5300, the system begins, atStep 5310, by identifying a form used to collect one or more pieces ofpersonal data. The particular entity may include, for example, aparticular organization, company, sub-organization, etc. In particularembodiments, the one or more data assets (e.g., data systems) mayinclude, for example, any processor or database that collects,processes, contains, and/or transfers data (e.g., such as a softwareapplication, “internet of things” computerized device, database,website, data-center, server, etc.). The one or more forms may ask forpersonal data, and the one or more data assets may store personal datafor clients or customers. In embodiment described herein, personal datamay include, for example: (1) the name of a particular data subject(which may be a particular individual); (2) the data subject's address;(3) the data subject's telephone number; (4) the data subject's e-mailaddress; (5) the data subject's social security number; (6) informationassociated with one or more of the data subject's credit accounts (e.g.,credit card numbers); (7) banking information for the data subject; (8)location data for the data subject (e.g., their present or pastlocation); (9) internet search history for the data subject; and/or (10)any other suitable personal information, such as other personalinformation discussed herein.

In particular embodiments, the system is configured to identify a formvia one or more method that may include one or more website scanningtools (e.g., web crawling). The system may also receive an indicationthat a user is completing a form (e.g., a webform via a website)associated with the particular organization (e.g., a form to completefor a particular privacy campaign).

The form may include, for example, one or more fields that include theuser's e-mail address, billing address, shipping address, and paymentinformation for the purposes of collected payment data to complete acheckout process on an e-commerce website. The system may, for example,be configured to track data on behalf of an entity that collects and/orprocesses personal data related to: (1) who consented to the processingor collection of personal data (e.g., the data subject themselves or aperson legally entitled to consent on their behalf such as a parent,guardian, etc.); (2) when the consent was given (e.g., a date and time);(3) what information was provided to the consenter at the time ofconsent (e.g., a privacy policy, what personal data would be collectedfollowing the provision of the consent, for what purpose that personaldata would be collected, etc.); (4) how consent was received (e.g., oneor more copies of a data capture form, webform, etc. via which consentwas provided by the consenter); (5) when consent was withdrawn (e.g., adate and time of consent withdrawal if the consenter withdraws consent);and/or (6) any other suitable data related to receipt or withdrawal ofconsent.

Continuing to Step 5320, the system is configured to determine one ormore data assets of a plurality of data assets of the organization whereinput data of the form is transmitted. In particular embodiments, thesystem may determine one or more data assets of the organization thatreceive the form data provided by the user in the form (e.g., webform).In particular embodiments, the system is configured to identify the oneor more data assets using one or more data modeling techniques. Asdiscussed more fully above, a data model may store the followinginformation: (1) the entity that owns and/or uses a particular dataasset (e.g., such as a primary data asset, an example of which is shownin the center of the data model in FIG. 4 ); (2) one or more departmentswithin the organization that are responsible for the data asset; (3) oneor more software applications that collect data (e.g., personal data)for storage in and/or use by the data asset; (4) one or more particulardata subjects (or categories of data subjects) that information iscollected from for use by the data asset; (5) one or more particulartypes of data that are collected by each of the particular applicationsfor storage in and/or use by the data asset; (6) one or more individuals(e.g., particular individuals or types of individuals) that arepermitted to access and/or use the data stored in, or used by, the dataasset; (7) which particular types of data each of those individuals areallowed to access and use; and (8) one or more data assets (destinationassets) that the data is transferred to for other use, and whichparticular data is transferred to each of those data assets.

As may be understood in light of this disclosure, the system may utilizea data model (e.g., or one or more data models) to identify the one ormore data assets associated with the particular entity that receiveand/or store particular form data.

At Step 5330, the system is configured to add the one or more dataassets to the third-party data repository with an electronic link to theform. In particular embodiments, a third-party data repository systemmay electronically link the form to the one or more data assets thatprocessor or store the form data of the form. Next, at Step 5340, inresponse to a user submitting the form, the system is configured tocreate a unique subject identifier associated with the user. The systemis configured to generate, for each data subject that completes the form(e.g., a webform), a unique identifier. The system may, for example: (1)receive an indication that the form has been completed with the formincluding a piece of personal data; (2) identify a data subjectassociated with the piece of personal data; (3) determine whether thecentral repository system is currently storing data associated with thedata subject; and (4) in response to determining that one or more dataassets of the plurality of data assets is not currently storing dataassociated with the data subject (e.g., because the data subject is anew data subject), generate the unique identifier.

In particular embodiments, the unique identifier may include any uniqueidentifier such as, for example: (1) any of the one or more pieces ofpersonal data collected, stored, and/or processed by the system (e.g.,name, first name, last name, full name, address, phone number, e-mailaddress, etc.); (2) a unique string or hash comprising any suitablenumber of numerals, letters, or combination thereof; and/or (3) anyother identifier that is sufficiently unique to distinguish between afirst and second data subject for the purpose of subsequent dataretrieval. In particular embodiments, the system is configured to assigna permanent identifier to each particular data subject. In otherembodiments, the system is configured to assign one or more temporaryunique identifiers to the same data subject.

In particular embodiments, the system is configured to: (1) receive anindication of completion of a form associated with the organization by adata subject; (2) determine, based at least in part on searching aunique subject identifier database (e.g., a third-party datarepository), whether a unique subject identifier has been generated forthe data subject; (3) in response to determining that a unique subjectidentifier has been generated for the data subject, accessing the uniquesubject identifier database; (4) identify the unique subject identifierof the data subject based at least in part on form data provided by thedata subject in the completion of the form associated with theorganization; and (5) update the unique subject identifier database toinclude an electronic link between the unique subject identifier of thedata subject with each of (i) the form (e.g., including the form data)submitted by the data subject of each respective unique subjectidentifier, and (ii) one or more data assets that utilize the form dataof the form received from the data subject. In this way, as an entitycollects additional data for a particular unique data subject (e.g.,having a unique subject identifier, hash, etc.), the third party datarepository system is configured to maintain a centralized database ofdata collected, stored, and or processed for each unique data subject(e.g., indexed by unique subject identifier). The system may then, inresponse to receiving a data subject access request from a particulardata subject, fulfill the request substantially automatically (e.g., byproviding a copy of the personal data, deleting the personal data,indicating to the entity what personal data needs to be deleted fromtheir system and where it is located, etc.). The system may, forexample, automatically fulfill the request by: (1) identifying theunique subject identifier associated with the unique data subject makingthe request; and (2) retrieving any information associated with theunique data subject based on the unique subject identifier.

Continuing to Step 5350, the system is configured to transmit the uniquesubject identifier (i) to the third-party data repository and (ii) alongwith the form data provided by the user in the form, to the data asset.At Step 5360, the system is configured to digitally store the uniquesubject identifier (i) in the third-party data repository and (ii) alongwith the form data provided by the user in the form, in the data asset.As may understood in light of this disclosure, the system may then beconfigured to facilitate the receipt and centralized storage of personaldata for each of a plurality of respective data subjects and theassociated one or more data assets that process or store the form dataprovided by the data subject.

In particular embodiments, the system may be further configured forreceiving a data subject access request from the user, accessing thethird-party data repository to identify the unique subject identifier ofthe user, determining which one or more data assets of the plurality ofdata assets of the organization include the unique subject identifier,and accessing personal data (e.g., form data) of the user stored in eachof the one or more data assets of the plurality of data assets of theorganization that include the unique subject identifier. In particularembodiments, the data subject access request may be a subject's rightsrequest where the data subject may be inquiring for the organization toprovide all data that the particular organization has obtained on thedata subject or a data subject deletion request where the data subjectis requesting for the particular organization to delete all data thatthe particular organization has obtained on the data subject.

In particular embodiments, when the data subject access request is adata subject deletion request, in response to accessing the personaldata of the user stored in each of the one or more data assets of theplurality of data assets of the organization that include the uniquesubject identifier, the system deletes the personal data of the userstored in each of the one or more data assets of the plurality of dataassets of the organization that include the unique subject identifier.In some embodiments, when the data subject access request is a datasubject deletion request, the system may be configured to: (1) inresponse to accessing the personal data of the user stored in each ofthe one or more data assets of the plurality of data assets,automatically determine that a first portion of personal data of theuser stored in the one or more data assets has one or more legal basesfor continued storage; (2) in response to determining that the firstportion of personal data of the user stored in the one or more dataassets has one or more legal bases for continued storage, automaticallymaintain storage of the first portion of personal data of the userstored in the one or more data assets; (3) in response to determiningthat the first portion of personal data of the user stored in the one ormore data assets has one or more legal bases for continued storage,automatically maintaining storage of the first portion of personal dataof the user stored in the one or more data assets; and (4) automaticallyfacilitating deletion of a second portion of personal data of the userstored in the one or more data assets for which one or more legal basesfor continued storage cannot be determined, wherein the first portion ofthe personal data of the user stored in the one or more data assets isdifferent from the second portion of personal data of the user stored inthe one or more data assets.

In still other embodiments, the system is configured to scan a domain,site, or other suitable application or location to identify one or morecookies, one or more pixels, one or more forms, one or more JavaScriptelements, etc. In particular embodiments, the system may identify one ormore vendor elements (e.g., third-party vendors) implemented at aparticular webpage in order to map a consent transaction between a userand the third-party vendor to the user via a unique ID generated duringa particular browser session, application access, login, etc.

Data Transfer Risk Identification and Analysis

In particular embodiments, a Data Transfer Risk Identification System isconfigured to analyze one or more data systems (e.g., data assets),identify data transfers between/among those systems, apply data transferrules to each data transfer record, perform a data transfer assessmenton each data transfer record based on the data transfer rules to beapplied to each data transfer record, and calculate a risk score for thedata transfer based at least in part on the one or more data transferrisks associated with the data transfer record.

Various processes performed by the Data Transfer Risk IdentificationSystem may be implemented by Data Transfer Risk Identification Module5400. Referring to FIG. 54 , in particular embodiments, the system, whenexecuting the Data Transfer Risk Identification Module 5400, isconfigured for: (1) creating a data transfer record for a data transferbetween a first asset in a first location and a second asset in a secondlocation; (2) accessing a set of data transfer rules that are associatedwith the data transfer record; (3) performing a data transfer assessmentbased at least in part on applying the set of data transfer rules on thedata transfer record; (4) identifying one or more data transfer risksassociated with the data transfer record, based at least in part on thedata transfer assessment; (5) calculating a risk score for the datatransfer based at least in part on the one or more data transfer risksassociated with the data transfer record; and (6) digitally storing therisk score for the data transfer.

When executing the Data Transfer Risk Identification Module 5400, thesystem begins, at Step 5410, by creating a data transfer record for adata transfer between a first asset in a first location and a secondasset in a second location. The data transfer record may be created foreach transfer of data between a first asset in a first location and asecond asset in a second location where the transfer record may alsoinclude information regarding the type of data being transferred, a timeof the data transfer, an amount of data being transferred, etc. In someembodiments, the system may access a data transfer record that may havealready been created by the system.

In various embodiments, the system may be configured to determine inwhich of the one or more defined plurality of physical locations eachparticular data system is physically located. In particular embodiments,the system is configured to determine the physical location based atleast in part on one or more data attributes of a particular data asset(e.g., data system) using one or more data modeling techniques (e.g.,using one or more suitable data modeling techniques described herein).In some embodiments, the system may be configured to determine thephysical location of each data asset based at least in part on anexisting data model that includes the data asset. In still otherembodiments, the system may be configured to determine the physicallocation based at least in part on an IP address and/or domain of thedata asset (e.g., in the case of a computer server or other computingdevice) or any other identifying feature of a particular data asset.

In particular embodiments, the system is configured to identify one ormore data elements stored by the one or more data systems that aresubject to transfer (e.g., transfer to the one or more data systems suchas from a source asset, transfer from the one or more data systems to adestination asset, etc.). In particular embodiments, the system isconfigured to identify a particular data element that is subject to suchtransfer (e.g., such as a particular piece of personal data or otherdata). In some embodiments, the system may be configured to identify anysuitable data element that is subject to transfer and includes personaldata.

In any embodiment described herein, personal data may include, forexample: (1) the name of a particular data subject (which may be aparticular individual); (2) the data subject's address; (3) the datasubject's telephone number; (4) the data subject's e-mail address; (5)the data subject's social security number; (6) information associatedwith one or more of the data subject's credit accounts (e.g., creditcard numbers); (7) banking information for the data subject; (8)location data for the data subject (e.g., their present or pastlocation); (9) internet search history for the data subject; and/or (10)any other suitable personal information, such as other personalinformation discussed herein.

In some embodiments, with regard to the location of the one or more dataassets, the system may define a geographic location of the one or moredata assets. For example, define each of the plurality of physicallocations based at least in part on one or more geographic boundaries.These one or more geographic boundaries may include, for example: (1)one or more countries; (2) one or more continents; (3) one or morejurisdictions (e.g., such as one or more legal jurisdictions); (4) oneor more territories; (5) one or more counties; (6) one or more cities;(7) one or more treaty members (e.g., such as members of a trade,defense, or other treaty); and/or (8) any other suitable geographicallydistinct physical locations.

Continuing to Step 5420, the system is configured for accessing a set ofdata transfer rules that are associated with the data transfer record.The system may apply data transfer rules to each data transfer record.The data transfer rules may be configurable to support different privacyframeworks (e.g., a particular data subject type is being transferredfrom a first asset in the European Union to a second asset outside ofthe European Union) and organizational frameworks (e.g., to support thedifferent locations and types of data assets within an organization).The applied data transfer rules may be automatically configured by thesystem (e.g., when an update is applied to privacy rules in a country orregion) or manually adjusted by the particular organization (e.g., by aprivacy officer of the organization). The data transfer rules to beapplied may vary based on the data being transferred.

As may be understood from this disclosure, the transfer of personal datamay trigger one or more regulations that govern such transfer. Inparticular embodiments, personal data may include any data which relateto a living individual who can be identified: (1) from the data; or (2)from the data in combination with other information which is in thepossession of, or is likely to come into the possession of a particularentity. In particular embodiments, a particular entity may collect,store, process, and/or transfer personal data for one or more customers,one or more employees, etc.

In various embodiments, the system is configured to use one or more datamodels of the one or more data assets (e.g., data systems) to analyzeone or more data elements associated with those assets to determinewhether the one or more data elements include one or more data elementsthat include personal data and are subject to transfer. In particularembodiments, the transfer may include, for example: (1) an internaltransfer (e.g., a transfer from a first data asset associated with theentity to a second data asset associated with the entity); (2) anexternal transfer (e.g., a transfer from a data asset associated withthe entity to a second data asset associated with a second entity);and/or (3) a collective transfer (e.g., a transfer to a data assetassociated with the entity from an external data asset associated with asecond entity).

The particular entity may include, for example, a particularorganization, company, sub-organization, etc. In particular embodiments,the one or more data assets (e.g., data systems) may include, forexample, any entity that collects, processes, contains, and/or transfersdata (e.g., such as a software application, “internet of things”computerized device, database, web site, data-center, server, etc.). Forexample, a first data asset may include any software or device utilizedby a particular entity for such data collection, processing, transfer,storage, etc. In various embodiments, the first data asset may be atleast partially stored on and/or physically located in a particularlocation. For example, a server may be located in a particular country,jurisdiction, etc. A piece of software may be stored on one or moreservers in a particular location, etc.

In particular embodiments, the system is configured to identify the oneor more data systems using one or more data modeling techniques. Asdiscussed more fully above, a data model may store the followinginformation: (1) the entity that owns and/or uses a particular dataasset (e.g., such as a primary data asset, an example of which is shownin the center of the data model in FIG. 4 ); (2) one or more departmentswithin the organization that are responsible for the data asset; (3) oneor more software applications that collect data (e.g., personal data)for storage in and/or use by the data asset; (4) one or more particulardata subjects (or categories of data subjects) that information iscollected from for use by the data asset; (5) one or more particulartypes of data that are collected by each of the particular applicationsfor storage in and/or use by the data asset; (6) one or more individuals(e.g., particular individuals or types of individuals) that arepermitted to access and/or use the data stored in, or used by, the dataasset; (7) which particular types of data each of those individuals areallowed to access and use; and (8) one or more data assets (destinationassets) that the data is transferred to for other use, and whichparticular data is transferred to each of those data assets.

As may be understood in light of this disclosure, the system may utilizea data model (e.g., or one or more data models) of data assetsassociated with a particular entity to identify the one or more datasystems associated with the particular entity.

Next, at Step 5430, the system is configured for performing a datatransfer assessment based at least in part on applying the set of datatransfer rules on the data transfer record. The data transfer assessmentperformed by the system may identify risks associated with the datatransfer record. At Step 5440, the system is configured for identifyingone or more data transfer risks associated with the data transferrecord, based at least in part on the data transfer assessment. The oneor more data transfer risks may include, for example, a source locationof the first location of the one or more first data asset of the datatransfer, a destination location of the second location of the one ormore second data asset of the data transfer, one or more type of databeing transferred as part of the data transfer (e.g., personal data orsensitive data), a time of the data transfer (e.g., date, day of theweek, time, month, etc.), an amount of data being transferred as part ofthe data transfer.

Continuing to Step 5450, the system is configured for calculating a riskscore for the data transfer based at least in part on the one or moredata transfer risks associated with the data transfer record. The riskscore may be calculated in a multitude of ways, and may include one ormore data transfer risks such as a source location of the data transfer,a destination location of the data transfer, the type of data beingtransferred, a time of the data transfer, an amount of data beingtransferred, etc. Additionally, the system may apply weighting factors(e.g., manually or automatically determined) to the risk factors.Further, in some implementations, the system may include a thresholdrisk score where a data transfer may be terminated if the data transferrisk score indicates a higher risk than the threshold risk score (e.g.,the data transfer risk score being higher than the threshold riskscore).

In some embodiments, the system may compare the risk score for the datatransfer to a threshold risk score, determine that the risk score forthe data transfer is a greater risk than the threshold risk score, andin response to determining that the risk score for the data transfer isa greater risk than the threshold risk score, taking one or more action.The one or more action may include, for example, provide the datatransfer record to one or more individuals (e.g., a privacy officer) forreview of the data transfer record where the one or more individuals maymake a decision to approve the data transfer or terminate the datatransfer. In some implementations, the system may automaticallyterminate the data transfer.

In some implementations, the system may generate a secure link betweenone or more processors associated with the first asset in the firstlocation and one or more processors associated with the second asset inthe second location, and the system may further provide the datatransfer via the secure link between the one or more processorsassociated with the first asset in the first location and the one ormore processors associated with the second asset in the second location.

In various embodiments, the system may determine a weighting factor foreach of the one or more data transfer risks, determine a risk rating foreach of the one or more data transfer risks, and calculate the risklevel for the data transfer based upon, for each respective one of theone or more data transfer risks, the risk rating for the respective datatransfer risk and the weighting factor for the respective data transferrisk.

At Step 5460, the system continues by digitally storing the risk scorefor the data transfer. In various embodiments, the system may continueby transferring the data between the first asset in the first locationand the second asset in the second location. In some embodiments, thesystem may be configured to substantially automatically flag aparticular transfer of data as problematic (e.g., because the transferdoes not comply with an applicable regulation). For example, aparticular regulation may require data transfers from a first asset to asecond asset to be encrypted.

Although one or more transfers discussed herein are described in thecontext of a data transfer between a first and second data asset indistinct locations, it should be understood that, in other embodiments,the data transfer may include a transfer of data between a data asset ina first location and a user in a second location (e.g., a user accessingthe data at the first data asset in the first location). In still otherembodiments, the transfer(s) may involve a transfer between a first dataasset in a first location and one or more systems related to one or moreentity partners, etc.

Automated Classification of Personal Information from Documents

In any embodiment described herein, an automated classification systemmay be configured to substantially automatically classify one or morepieces of personal information in one or more documents (e.g., one ormore text-based documents, one or more spreadsheets, one or more PDFs,one or more webpages, etc.). In particular embodiments, the system maybe implemented in the context of any suitable privacy compliance system,which may, for example, be configured to calculate and assign asensitivity score to a particular document based at least in part on oneor more determined categories of personal information (e.g., personaldata) identified in the one or more documents. As understood in the art,the storage of particular types of personal information may be governedby one or more government or industry regulations. As such, it may bedesirable to implement one or more automated measures to automaticallyclassify personal information from stored documents (e.g., to determinewhether such documents may require particular security measures, storagetechniques, handling, whether the documents should be destroyed, etc.).

FIG. 55 is a flowchart of process steps that the system may perform inthe automatic classification of personal information in an electronicdocument. When executing the Automated Classification Module 5500, thesystem begins, at Step 5510, by receiving and/or retrieving one or moreelectronic documents for analysis and classification. The system may,for example, receive a particular document from a user for analysis. Inother embodiments, the system may be configured to automatically scanelectronic documents stored on a system (e.g., on one or more servers,in one or more databases, or in any other suitable location) to classifyany personal information that may be stored therein. In variousembodiments, the one or more electronic documents may include, forexample: (1) one or more PDFs; (2) one or more spreadsheets; (3) one ormore text-based documents; (4) one or more audio files; (5) one or morevideo files; (6) one or more webpages; and/or (7) any other suitabletype of document.

FIG. 56 depicts an exemplary electronic document that the system mayreceive and/or retrieve for analysis. As may be understood from FIG. 56(e.g., a PDF or other text-based document), the electronic documentcontains employee information such as: (1) first name; (2) last name;(3) social security number; (3) address; (4) marital status; (5) phonenumber; (6) employer information; (7) etc.

Continuing to Step 5520, the system is configured to use one or morenatural language processing techniques to determine data from the one ormore electronic documents into one or more structured objects. Thesystem may, for example, use one or more optical character recognition(OCR) techniques to identify particular text in the electronicdocuments. In some embodiments, the system may be configured to use oneor more audio processing techniques to identify one or more words in anaudio recording, etc.

The system, in particular embodiments, may be configured to: (1) parsethe document to identify context for particular identified text (e.g.,identify context based at least in part on proximity to other identifiedtext, etc.); (2) parse out labels from the document; and (3) parse outvalues for the various labels. The system may, for example, identifyparticular categories of information contained in document. As may beunderstood from FIG. 3 , the system may be configured to identifyparticular labels such as, for example: (1) first name; (2) last name;(3) city; and (4) so on. The system may be further configured toidentify values associated with each label such as: (1) DOE for lastname; (2) JOHN for first name; (3) etc. The system may be configured todetermine these values based on, for example: (1) a proximity of thevalues to the labels; (2) a position of the values relative to thelabels; (3) one or more natural language processing techniques (e.g.,the system may be configured to identify John as a name, and thenassociate John with the identified label for name, etc.). The system maythen be further configured to electronically associate the identifiedvalues with their respective labels (e.g., in computer memory).

In any embodiment described herein, the system may then generate aclassification of one or more structured objects identified using thenatural language processing techniques described above. For example, thesystem may be configured to generate a catalog of labels identified inthe electronic document. FIG. 57 depicts an illustration of one or moreobject that the system has generated based on the document shown in FIG.56 as a result of the scanning described above.

Continuing to Step 5530, the system is configured to classify each ofthe one or more structured objects based on one or more attributes ofthe structured objects. For example, the system may be configured to usecontextual information, sentiment, and/or syntax to classify each of thestructured objects. FIG. 58 depicts an exemplary classification of thestructured objects cataloged from FIG. 57 . As may be understood fromthis Figure, the system may be configured to group objects based in parton a type of information. For example, the various objects related to anindividual's name (e.g., first name, last name, etc.) may be groupedinto a single classification. The system may, for example, be configuredto automatically classify the one or more objects based on: (1) theobject's proximity in the particular document; (2) one or more headingsidentified in the document; and/or (3) any other suitable factor. Forexample, in various embodiments, the system is configured to use one ormore machine learning and/or natural language techniques to identify arelation between objects.

The system may then be configured to identify one or more objectswithout associated values and remove those objects from theclassification. FIGS. 59-60 depict a visual representation of objectswithout associated values from the PDF shown in FIG. 56 being blackedout and removed from the classification. The system may, for example, beconfigured to generate an initial classification based on the document,and then modify the classification based on one or more identifiedvalues in the specific document.

Continuing to Step 5540, the system is configured to categorize each ofthe one or more structured objects based at least in part on asensitivity of information determined based on the one or moreattributes of the objects. The system may be configured to determine thecategorization based on sensitivity based on, for example: (1) one ormore predefined sensitivities for particular categories of information;(2) one or more user-defined sensitivities; (3) one or moresensitivities determined automatically based on one or more prevailingindustry or government regulations directed toward the type ofinformation associated with the objects; (4) etc.

FIG. 62 depicts an exemplary mapping of values and structured objectsbased on a sensitivity of the structured objects. As may be understoodfrom this figure, the system is configured to cross-reference thecategorization of structured objects with a database of personal dataclassification, which may, for example, identify a sensitivity ofparticular categories of structured objects (e.g., personallyidentifiable information, sensitive personal data, partial PII, personaldata, not personal data, etc.). The system may then be configured to mapthe results as shown in FIG. 62 .

Next, at Step 5550, the system is configured to rate the accuracy of thecategorization performed at Step 5540. The system may, for example, beconfigured to rate the categorization by comparing the categorizationdetermined for a similar electronic document (e.g., a second electronicdocument that includes the same form filled out by another individualthan John Doe). In other embodiments, the system may be configured torate the accuracy of the categorization based on one or more attributes(e.g., one or more values) of the structured objects. The system may,for example, analyze the value for a particular object to determine anaccuracy of the categorization of the object. For example, an object forfirst name may be categorized as “employee information,” and the systemmay be configured to analyze a value associated with the object todetermine whether the categorization is accurate (e.g., analyze thevalue to determine whether the value is, in fact, a name). The systemmay, for example, determine that the accuracy of the categorization isrelatively low in response to determining that a value for the “firstname” object contains a number string or a word that is nottraditionally a name (e.g., such as ‘attorney’ or another job title, aphone number, etc.). The system may determine a character type (e.g.,set of numbers, letters, a combination of numbers and letters, etc.) foreach object and a character type for each value of the object todetermine the accuracy of the categorization. The character type foreach object and each value of the object may be compared to determinethe accuracy of the categorization by the system.

Continuing to Step 5560, the system is configured to generate asensitivity score for each element in the one or more electronicdocuments and each document as a whole based at least in part on thecategory and sensitivity of each object. The system may, for example,assign a relative sensitivity to the document based on each relativesensitivity score assigned to each object identified in the document.The system may, in various embodiments, calculate a sensitivity scorefor each object based at least in part on a confidence in the accuracyof the categorization of the object and the sensitivity assigned to theparticular categorization.

CONCLUSION

Although embodiments above are described in reference to various privacymanagement systems, it should be understood that various aspects of thesystem described above may be applicable to other privacy-relatedsystems, or to other types of systems, in general.

Also, although various embodiments are described as having the systemanalyze a data subject's interaction with email, text messages (e.g.,SMS or MMS messages), or other electronic correspondence to determinewhether the data subject actively does business with a particularentity, in other embodiments, the system may make this determinationwithout analyzing electronic correspondence (e.g., emails or texts) or adata subject's interaction with electronic correspondence. For example,in particular embodiments, the system may automatically determinewhether a data subject has requested that a particular entity not sendemails to the data subject and, at least partially in response to makingthis determination, automatically generate, populate, and/or submit adata subject access request to the particular entity. Such a datasubject access request may include, for example, any of the various datasubject access requests described above (e.g., a request to delete allof the data subject's personal data that is being processed by theparticular entity). The system may execute similar functionality inresponse to determining that the data subject has requested that theparticular entity not send text (e.g., SMS or MMS) messages to the datasubject, call the data subject, etc.

It should be understood that, in various embodiments, the system maygenerate, populate, and/or submit any of the data subject accessrequests referenced above electronically (e.g., via a suitable computingnetwork).

While this specification contains many specific embodiment details,these should not be construed as limitations on the scope of anyinvention or of what may be claimed, but rather as descriptions offeatures that may be specific to particular embodiments of particularinventions. Certain features that are described in this specification inthe context of separate embodiments may also be implemented incombination in a single embodiment. Conversely, various features thatare described in the context of a single embodiment may also beimplemented in multiple embodiments separately or in any suitablesub-combination. Moreover, although features may be described above asacting in certain combinations and even initially claimed as such, oneor more features from a claimed combination may in some cases be excisedfrom the combination, and the claimed combination may be directed to asub-combination or variation of a sub-combination.

Similarly, while operations are depicted in the drawings in a particularorder, this should not be understood as requiring that such operationsbe performed in the particular order shown or in sequential order, orthat all illustrated operations be performed, to achieve desirableresults. In certain circumstances, multitasking and parallel processingmay be advantageous. Moreover, the separation of various systemcomponents in the embodiments described above should not be understoodas requiring such separation in all embodiments, and it should beunderstood that the described program components and systems maygenerally be integrated together in a single software product orpackaged into multiple software products.

Many modifications and other embodiments of the invention will come tomind to one skilled in the art to which this invention pertains havingthe benefit of the teachings presented in the foregoing descriptions andthe associated drawings. Therefore, it is to be understood that theinvention is not to be limited to the specific embodiments disclosed andthat modifications and other embodiments are intended to be includedwithin the scope of the appended claims. Although specific terms areemployed herein, they are used in a generic and descriptive sense onlyand not for the purposes of limitation.

What is claimed is:
 1. A method comprising: analyzing, by computinghardware, one or more pieces of computer code associated with a webformused to collect personal data to identify a software applicationconfigured to receive the personal data collected by the webform;transmitting, by the computing hardware, an instruction to a consentrepository to generate an electronic link at the consent repositoryassociating the webform and the software application; detecting, by thecomputing hardware, a submission of the webform and form data associatedwith the webform; generating, by the computing hardware and based on theform data, a unique subject identifier for a user associated with thesubmission of the webform; transmitting, by the computing hardware, aninstruction to the consent repository causing the consent repository tostore and associate the unique subject identifier and the form data;transmitting, by the computing hardware, an instruction to the softwareapplication causing the software application to process and associatethe unique subject identifier and the form data; detecting, by thecomputing hardware, a request for access to personal data associatedwith the user and request data associated with the request; determining,by the computing hardware and based on the request data, the uniquesubject identifier using the consent repository; determining, by thecomputing hardware and based on the unique subject identifier and theform data, the software application using the consent repository;retrieving, by the computing hardware and based on the unique subjectidentifier, the personal data from the software application; andgenerating, by the computing hardware, a graphical user interface fordisplay on a user device, the graphical user interface presenting thepersonal data.
 2. The method of claim 1, further comprising:transmitting an instruction to the consent repository causing theconsent repository to generate a data map comprising the unique subjectidentifier, an indication of the software application, and an electroniclink associating the unique subject identifier and the indication of thesoftware application.
 3. The method of claim 2, wherein determining thesoftware application using the consent repository comprises determiningthe software application based on the unique subject identifier usingthe data map.
 4. The method of claim 2, wherein transmitting theinstruction to the consent repository causing the consent repository togenerate the data map comprises using an application programminginterface to transmit the instruction to the consent repository causingthe consent repository to generate the data map.
 5. The method of claim1, wherein analyzing the webform to identify the software applicationcomprises: analyzing the webform to identify a processing activityassociated with the webform; and determining the software applicationbased on the processing activity using a data map associated with theprocessing activity.
 6. The method of claim 1, wherein generating theunique subject identifier comprises: determining that the consentrepository does not store data associated with the user; and in responseto determining that the consent repository does not store the dataassociated with the user, generating the unique subject identifier. 7.The method of claim 1, wherein generating the unique subject identifiercomprises: detecting browser data in a browser application executed on auser device, the browser data comprising user data; and generating theunique subject identifier based on the user data.
 8. A systemcomprising: a non-transitory computer-readable medium storinginstructions; and processing hardware communicatively coupled to thenon-transitory computer-readable medium, wherein the processing hardwareis configured to execute the instructions and thereby perform operationscomprising: scanning one or more pieces of computer code associated witha webform used to collect personal data to determine a destinationserver associated with a storage location identified in the one or morepieces of computer code to which the personal data collected by thewebform is transmitted; transmitting an instruction to a consentrepository to generate an electronic link at the consent repositoryassociating the webform and the destination server; detecting asubmission of the webform and form data associated with the webform;determining a unique subject identifier for a user associated with thesubmission of the webform based on the form data; transmitting aninstruction to the consent repository causing the consent repository tostore and associate the unique subject identifier and the form data;transmitting an instruction to the destination server causing thedestination server to store and associate the unique subject identifierand the form data; detecting a request for access to personal dataassociated with the user and request data associated with the request;determining the unique subject identifier based on the request datausing the consent repository; determining the destination server basedon the unique subject identifier and the form data using the consentrepository; retrieving a subset of the personal data from thedestination server based on the unique subject identifier; andgenerating a graphical user interface for display on a user device, thegraphical user interface presenting the personal data.
 9. The system ofclaim 8, wherein determining the unique subject identifier comprises:determining that the consent repository stores data associated with theuser; and in response to determining that the consent repository storesthe data associated with the user, retrieving the unique subjectidentifier from the consent repository.
 10. The system of claim 8,wherein detecting the request for access to the personal data comprisesdetecting browser data in a browser application executed on a userdevice, the browser data comprising the request data and a data subjectparameter identifying the user.
 11. The system of claim 8, whereindetecting the submission of the webform and the form data comprisesdetecting browser data in a browser application executed on a userdevice, the browser data comprising the form data and indication of thesubmission of the webform.
 12. The system of claim 8, wherein theoperations further comprise: transmitting an instruction to the consentrepository causing the consent repository to modify a data mapassociated with the unique subject identifier to include an indicationof the destination server and an electronic link associating the uniquesubject identifier and the indication of the destination server.
 13. Thesystem of claim 12, wherein the operations further comprise: determininga second server based on the unique subject identifier using the datamap; and retrieving a second subset of the personal data from the secondserver based on the unique subject identifier.
 14. The system of claim8, wherein generating the graphical user interface comprises: generatingthe graphical user interface for a browser application executed on auser device by configuring a display element configured to display thepersonal data on the graphical user interface; and transmitting aninstruction to the browser application causing the browser applicationto retrieve the personal data and present the graphical user interfaceon the user device.
 15. A non-transitory computer-readable mediumstoring computer-executable instructions that, when executed byprocessing hardware, configure the processing hardware to performoperations comprising: analyzing one or more pieces of computer codeassociated with a webform used to collect personal data to identify adatabase configured to receive the personal data collected by thewebform; transmitting an instruction to a consent repository to generatean electronic link at the consent repository associating the webform andthe database; detecting a submission of the webform and form dataassociated with the webform, the form data comprising consent data;determining a unique subject identifier for a user associated with thesubmission of the webform based on the form data; transmitting aninstruction to the consent repository causing the consent repository tostore and associate the unique subject identifier and the form data;transmitting an instruction to the database causing the database tostore and associate the unique subject identifier and the form data;receiving a request for access to personal data associated with the userand request data associated with the request; determining the uniquesubject identifier using the consent repository based on the requestdata; determining the database using the consent repository based on theunique subject identifier and the form data; retrieving the personaldata from the database based on the unique subject identifier; andgenerating a graphical user interface for display on a user device, thegraphical user interface presenting the personal data.
 16. Thenon-transitory computer-readable medium of claim 15, wherein theoperations further comprise: transmitting an instruction to the consentrepository causing the consent repository to generate a data inventorycomprising the unique subject identifier, an indication of the database,the consent data, and an electronic link associating the unique subjectidentifier, the consent data, and the indication of the database. 17.The non-transitory computer-readable medium of claim 16, whereindetermining the database using the consent repository comprisesdetermining the database based on the unique subject identifier usingthe data inventory.
 18. The non-transitory computer-readable medium ofclaim 16, wherein: retrieving the personal data from the databasecomprises determining the consent database based on the unique subjectidentifier using the data inventory; and retrieving the personal datafrom the database is further based on the consent data.
 19. Thenon-transitory computer-readable medium of claim 15, wherein generatingthe graphical user interface comprises: generating the graphical userinterface for a browser application executed on a user device based onthe consent data by configuring a first display element configured todisplay the personal data on the graphical user interface and excludinga second display element configured to display a denial of access to thepersonal data from the graphical user interface; and transmitting aninstruction to the browser application causing the browser applicationto retrieve the personal data and present the graphical user interfaceon the user device.
 20. The non-transitory computer-readable medium ofclaim 15, wherein detecting the submission of the webform and form datacomprises detecting browser data in a browser application executed on auser device, the browser data comprising the consent data.